Health and Environment Building Mobile Networks 2007 - English

GSM Europe Health &
Environment
Building Mobile Networks:
European Mobile Operator
Responses to Public Concerns
November 2007
Release version
Ovum Consulting, Cardinal Tower, 12 Farringdon Road, London EC1M 3HS
Telephone +44 (0) 20 7551 9000 - Facsimile +44 (0) 20 7551 9090/1
www.ovumconsulting.com
BUILDING MOBILE NETWORKS: EUROPEAN MOBILE OPERATOR
RESPONSES TO PUBLIC CONCERNS
BUILDING MOBILE NETWORKS: 22
EUROPEAN MOBILE OPERATOR RESPONSES TO PUBLIC CONCERNS
LEGAL NOTICE:
Neither the GSM Association nor its Members or Associate Members are responsible for the use that might be
made of this publication. The views expressed in this publication are the sole responsibility of the author(s)
and do not necessarily reflect the views of the GSM Association, their Members or Associate Members
This study was commissioned by GSM Europe, the European interest group of the GSM Association, and
undertaken by Ovum Consulting. The report is based on responses provided by the members of GSM Europe,
mobile operators and national trade associations, across EU-27 member states and Switzerland during the
period of August/September 2007.
Contents
1. Executive Summary................................................................................................... 5
2. Introduction............................................................................................................ 12
2.1 Study and scope of work ..........................................................................................12
2.2 Report structure ......................................................................................................12
2.3 Social and economic contribution of mobile communication............................................13
2.4 Mobile technology and network infrastructure ..............................................................13
2.4.1 How mobile networks work.....................................................................................13
2.4.2 New technologies and service evolution....................................................................14
2.5 The need for continuous base stations deployment .......................................................15
2.6 GSM Europe’s activities ............................................................................................16
3. Implementation review of GSM Europe Recommendations ..................................... 20
3.1 Background ............................................................................................................20
3.2 Survey participants ..................................................................................................20
3.3 General conclusions across the EU .............................................................................21
3.4 The impact of GSM Europe Recommendations..............................................................25
3.5 General conclusions .................................................................................................36
4. Research support .................................................................................................... 38
4.1 Background ............................................................................................................38
4.2 Current status: European Commission - EU .................................................................38

U
4.3 The involvement of GSM Europe and GSMA .................................................................40
4.4 International Research .............................................................................................41
4.4.1 World Health Organization......................................................................................41
4.4.2 Precautionary policies ............................................................................................42
4.4.3 Other reports .......................................................................................................43
Annex I - Country profiles ........................................................................................... 45
I.1 Austria ...................................................................................................................46
I.2 Belgium ..................................................................................................................48
I.3 Bulgaria ..................................................................................................................49

I.4 Cyprus....................................................................................................................51
I.5 Czech Republic ........................................................................................................53
I.6 Denmark.................................................................................................................55
I.7 Estonia ...................................................................................................................55
I.8 Finland ...................................................................................................................55
I.9 France ....................................................................................................................57
I.10 Germany...............................................................................................................59
I.11 Greece..................................................................................................................62
I.12 Hungary................................................................................................................64
I.13 Ireland..................................................................................................................66
I.14 Italy .....................................................................................................................68
I.15 Latvia ...................................................................................................................70
I.16 Lithuania...............................................................................................................72
I.17 Luxembourg ..........................................................................................................73
I.18 Malta ....................................................................................................................74
I.19 The Netherlands .....................................................................................................75
I.20 Poland ..................................................................................................................77
I.21 Portugal ................................................................................................................79
I.22 Romania ...............................................................................................................81
I.23 Slovakia................................................................................................................83
I.24 Slovenia................................................................................................................85
I.25 Spain....................................................................................................................86
I.26 Sweden.................................................................................................................88
I.27 Switzerland ...........................................................................................................90
I.28 United Kingdom .....................................................................................................92
Annex II – Base Station Planning Permission in Europe ............................................. 95
II.1 Cross-country analysis: Timescales............................................................................95
II.2 Country data ..........................................................................................................96
Annex III – GSM Europe Health & Environment: Recommendation on Network Rollout
Good Practice ............................................................................................................ 109
1. Executive Summary
Mobile network infrastructure and the adoption of mobile services are now considered as key
indicators of European economies. To ensure national coverage, mobile operators are required to
install base stations across the country so that every user is able to benefit from the use of
mobile services.
Base stations are installed to provide geographic coverage and additional network capacity
where needed. The introduction of new mobile services (e.g. 3G) requires additional,
technology-specific base stations. Operators may be required, as a condition of their licence, to
install base stations nationally to meet government or regulatory coverage targets, and they are
increasingly required to support increasing demand for concurrent calls as a base station can
only carry a certain number of calls whilst providing the required service quality.
The installation of base station facilities necessary for network deployment has increased the
public concern toward the alleged health impact of radio signals and other environmental
concerns. The mobile industry recognises that public fears should be addressed as a matter of
principle and in an open and transparent manner.
Ovum Consulting has conducted a survey with all GSM Europe (GSME) Members in the European
Union Member States and Switzerland to assess actions taken by mobile operators in relation to
the GSME Recommendations 1 , a self-regulatory framework on good practice for network rollout.
The main conclusions of the survey of mobile operators and trade associations are summarised
below:
• There is strong support for the GSME Recommendations as shown below. The industry
recognises public concerns and takes actions to mitigate these concerns, e.g.
establishing formal processes for information provision to the public and the authorities,
implementing site sharing and using alternative designs to minimise the visual impact of
sites. 90% of operators follow a company or national policy for good practice of network
rollout.
• For 96% of the operators, processes are in place to facilitate information exchange
between the industry and key stakeholders. In 41% of the cases, these processes are a
mandatory requirement. Voluntary initiatives by operators exceed 50% of the cases.
• Operators use a variety of methods to inform key stakeholders, primarily local

authorities, public or local communities and the regulator. Other interest groups include
media, health agencies, other mobile operators, landlords, politicians and key-opinion
leaders.
1
http://www.gsmworld.com/gsmeurope/documents/health/recommendation_network_rollout_good_practice.
pdf
Figure 1.1 & 1.2: Do you have a formal process to communicate and provide information
to the local authority/ the public on current and future network deployment plans? / How
do you facilitate the information flow?
Yes -
Yes - Voluntary, Information session/ road show 65%
Mandatory always used,
23% One to one sessions 63%
requirement,
41%
Conduct consultation process 50%
Seminars 40%
Letters to nearby residents 38%
Public/ media announcement 35%

No, 4%
Yes - Voluntary
Other 33%
(case by case),
33%
0% 20% 40% 60% 80%
Source: Ovum for GSME Study
• The survey indicates that operators proactively inform the public about their
requirements to install more antennas and sites categorisation. In over 75% and 60% of
the cases respectively, this is part of a voluntary programme.
Figure 1.3 & 1.4: Have you communicated the need to install more network antennas to
the public? / Do you conduct a consultation programme or involve local communities in
the categorisation of the sites 2 ?
Yes -
No, 2% Yes - Yes - Voluntary,
Yes - Mandatory, Mandatory, always used,
Voluntary 18% 18%
23%
(case by
case), 49%
No, 20%
Yes - Yes -
Voluntary
Voluntary,
(case by
always used, case), 43%
27%
• All operators share infrastructure for base stations, with more than 5 different types of
infrastructure being shared on average by an operator (e.g. tower or roof-mounted sites,
other telecommunication mast, other operator’s facilities and radio installations). The
2
Site categorisation is used in some countries to assess the level of consultation required. It is not a
measure of whether a site should or should not be progressed.
survey results show that 83% of 3G operators (with 2G operations) share sites with their
current 2G facilities/sites. All operators expect to maintain or increase (78% of
operators) their site sharing over the next 5 years.
• The use of alternative design and installations to reduce the visual impact of sites is a
key element of operators’ network rollout policies and the great majority of operators
(94%) use such techniques.
• All operators report that existing and new base stations comply with national, European
and/or international (ICNIRP 3 ) limits. All certifications are referred to exposure limits
that the operator’s country has adopted. The main reason for site measurements is to
respond to specific concerns of the public or others.
• Operators take special care of complaints and enquiries about base station planning and
EMF issues. Almost all operators (98%) responded that processes have been established
to address individual issues (e.g. consumer or site-specific).
Figure 1.5: What are the methods used to manage complaints and enquiries? (Multiple
responses possible)
Named contact personnel for liaison with local

78%
authorities
Employment of specialist staff for

communication/ issue management purposes 78%
with local residents
Telephone hotlines and web-sites that receive

65%
enquiries and dispatch information
Established Trade Association representing

network operators and providing coordination 61%
of information exchange
Established processes in the handling of

61%
enquiries with specified response time
Other 9%
0% 20% 40% 60% 80% 100%
• The approach to implementing the GSME recommendations varies between countries for
a number of reasons:
o the operator’s network rollout policy may need to comply with national
requirements for network rollout good practice. National policies do however
largely reflect GSM Europe Recommendations
3
ICNIRP: International Commission on Non-Ionizing Radiation Protection (http://www.icnirp.de)
o the level of public concern about EMF issues may be influenced by particular
interest groups and the media
o companies with multi-national operations may have network rollout guidelines

and policies which are followed by all group members
o a national trade association may coordinate national activity and help facilitate
EMF-related information flow to the local authorities and other key stakeholders
the requirements provided by national governments and agencies, and their
advice to the public vary (e.g. additional precautionary measures) resulting in
different needs for communications by the operator. Operators’ experience and
research indicates that such measures increase public concern 4
• Public concern is mainly expressed as related to possible health issues. Operators report
that significant complaints/ enquiries appear from only 7% of the sites which may
suggest that complaints are primarily local.
• There is no evidence for a general increase in public concern in the surveyed countries;
68% of operators responded that the level of concern had remained about the same over
the last 18 to 24 months or actually decreased. This is clearly shown in the following
table for each of the complaints categories.
Figure 1.6: Trends in the level of concerns (last 18-24 months)
Increased Decreased No change
Health 39% 8% 53%
Environment 28% 5% 67%
Aesthetic 19% 6% 75%
Technology 3% 14% 83%
Other 33% 0% 67%
The vast majority of the respondents (93%) stated that their actions related to GSM
Europe Recommendations have contributed to keep the level of complaints and enquiries
stable or even caused a decrease. This result may suggest that GSM Europe
Recommendations is a communication and implementation tool which when utilised by
the industry may control or lower public concerns.
4
Wiedemann et al, (2006). The Impacts of Precautionary Measures and the Disclosure of Scientific
Uncertainty on EMF Risk Perception and Trust. Journal of Risk Research, 9(4), pp. 361 - 372.
• GSM Europe members actively support independent research programmes in the areas
of mobile technologies, health, environment and social concerns. All operators contribute
to GSMA 5 programmes.
Base Station Planning Permission in Europe
• Requirements for permits for base station deployment vary largely from one European
country to the other. Procedures can be defined at different government levels, even
though generally the local authority (municipality) is the main point of referral for the
process. In addition, general requirements related to regional or national levels
legislation usually have to be met. Figure 1.6 shows timescales information contained in
the country tables presented in Annex II.
• As a general observation, delays are more likely to occur in cases in which a direct
authorizing intervention of the central government or of a number of bodies other than
the local planning authority is required. On the other hand some countries, such as Italy
and Portugal, have implemented tacit approval mechanisms to avoid delays related to
bureaucratic inefficiencies. Some countries have effective systems of exemptions for
small installations or certain site upgrades. When comparing this data with the 2004
report prepared by GSM Europe on the same topic 6 we notice that timescales for
permission granting have not changed dramatically.
Figure 1.7 Comparison between legal commitment and typically achieved timescales for
granting planning permission on a per country basis (# of months)
24
18
12
0
Lithuania
Finland
Ireland
Bulgaria
Netherlands
Republic
Belgium
Switzlerland
Austria
Slovenia
Denmark
Hungary
Italy
Spain
Poland
Portugal
Latvia
Malta
Romania
Slovakia
France
Cyprus
Germany
Kingdom
Greece
Sweden
United
Czech
The
legal commitment typical achieved
Health Research and Public Concern
5
GSMA is the global trade association representing of mobile operators using the GSM family of
technologies.
6
http://www.gsmworld.com/gsmeurope/documents/health/base_station_planning_report_europe_170504.pd
f
Extensive research has been conducted into possible health effects of exposure to many parts of
the frequency spectrum. The mobile industry is a significant contributor to national and
international research programs. The consensus of all reviews conducted so far indicates that
exposures below the limits recommended in the International Commission on Non-Ionizing
Radiation Protection (ICNIRP, 1998) EMF guidelines, covering the full frequency range from 0 -
300 GHz, do not produce any known adverse health effects. This has been reconfirmed by the
European Commissions independent scientific committee SCENIHR 7 However, there are gaps in
knowledge that still need to be filled in order that better health risk assessments can be made.
The World Health Organization (WHO) concludes that:
"With more and more research data available, it has become increasingly unlikely that
exposure to electromagnetic fields constitutes a serious health hazard, nevertheless,
some uncertainty remains. The original scientific discussion about the interpretation of
controversial results has shifted to become a societal as well as political issue." 8
Specifically for wireless networks the WHO states:
“Considering the very low exposure levels and research results collected to date, there
is no convincing scientific evidence that the weak RF signals from base stations and
wireless networks cause adverse health effects.” 9
Conclusions from the Survey
Based on the results presented above, a number of conclusions may be considered to enhance
the effectiveness of operators’ actions and initiatives:
1. It is crucial for the mobile industry to closely monitor and audit these processes in order to
be regularly reassured that informative programmes and other initiatives have the results
anticipated by the industry. It is reported that despite operators’ efforts and actions, public
and local authorities are not always receptive to accept the points presented in these
programmes due to lack of trust in the accuracy of and credibility in the information
provided. Governments on national, regional and local level therefore play a decisive role
in trusted and science-based communications. It is important that trust in these
communications is established with the recipients.
2. Risk communication activities must address public concerns. The industry is working to
provide community-specific information (e.g. to discuss particular base station
deployments and the benefits to the community where the deployment takes place) and to
help address local concerns through frequent interaction with interested stakeholders. The
level of activity should be proportionate to the level of public concern.
7
Scientific Committee on Emerging and Newly Identified Health Risks
(http://ec.europa.eu/health/ph_risk/committees/04_scenihr/04_scenihr_en.htm)
8
Source: WHO (2007) – What Are Electromagnetic Fields? (http://www.who.int/peh-
emf/about/WhatisEMF/en/index5.html)
9
Source: WHO (2006) – Fact Sheet No 304
3. It is important that national research programmes include open publication of the

outcomes of such studies as part of the information exchange processes. The conclusions
of these studies may also be used to inform government and operators’ EMF policies.
There is a need for better communication by governments to interested stakeholders of
the results and their interpretation. To avoid unnecessary duplication by national research
programmes it is recommended that these are based on the WHO 10 research agenda and
are co-ordinated at international and EU levels.
4. It is reported that public concern increases during the early phases of network rollout and
when there is media coverage (e.g. newspaper articles etc.) claiming unsubstantiated
health risks. The involvement of national governments with specialised communication
programmes, in conjunction with the mobile industry, can help facilitate public access to
updated information regarding EMF developments. Such programmes should be targeted
to address local issues and match the level of concern in that country. These programmes
should be designed to fill the communication gap, minimise unnecessary concerns and
ambiguous messages, and build the confidence of public and local communities.
10
World Health Organization, International EMF Project (www.who.int/peh-emf/)
2. Introduction
2.1 Study and scope of work
This paper was commissioned by GSM Europe, which represents all 2nd and 3rd generation GSM
family cellular network operators in Europe. The paper has been developed with the aims:
• to conduct a survey with GSM Europe Members in the European Union (EU) Member
states and Switzerland to assess actions taken by mobile operators in relation to the
GSME recommendations for good practice in network rollout
• to provide a country-by-country analysis of status and actions
• to summarise research support at the national, European and international level and
provide updated version of the Base Station Planning procedures for each one of the
Member States.
The report provides a detailed and accurate summary of actions, initiatives, voluntary codes of
practice and mandatory activities that mobile operators have been undertaking toward the
implementation of each separate element of the GSM Europe Recommendations. The report also
refers to actions being taken by other parties such as governments, national regulators, trade
associations and institutions, in that a complete picture is provided at a national level.
The report is based on responses from GSM Europe members to a survey questionnaire prepared
by Ovum and agreed with GSM Europe. The actions taken by GSM Europe members to
implement the GSM Europe Recommendations for Network Rollout, together with additional data
on Base Station Planning Procedures applicable to each country have been assessed.
2.2 Report structure

The report is structured in four Chapters and has two Annexes:
• Chapter 1: the Executive Summary
• Chapter 2: includes an introduction to mobile technology and the need for base station
deployment. GSM Europe’s activities related to health and environment are presented in
the last section of this chapter
• Chapter 3: presents the main conclusions, key findings and outcomes of the survey at an
EU level
• Chapter 4: provides a summary of the EMF research programs undertaken in EU and

international level. The World Health Organization (WHO)’s position in regards to alleged
health risks from mobile technology is briefly presented together with the
recommendations from the European Council and related actions
• Annex I: provides country-specific information about the implementation of GSM Europe

Recommendations. Annex I includes information on the level of public concern,
operators’ codes of practice and audit processes, voluntary actions by Mobile Network
Operators (MNOs), government actions and the exposure guidelines followed in each
country
• Annex II: provides a summary of Base Station planning procedures across the EU.
• Annex III: GSM Europe Recommendations on Network Rollout good practice is

presented.
2.3 Social and economic contribution of mobile

communication
In recent years, the mobile telecommunications sector has experienced enormous growth in
Europe and worldwide with continuously increasing penetration in all European and other
countries. New services have been introduced, enabled by more advanced networks. By the end
of June 2007, mobile connections had exceeded 700 million in Europe and are projected to 800
million by June 2008.
Mobile communication services are a major catalyst in improving the health, wealth, education
and social mobility of people and communities. Mobile services have transformed the way firms
operate and are a driving force to the social and economic development of countries in many
ways: contribution to GDP 11 growth; the direct and indirect creation of jobs and revenue
generation for governments. Mobile services play a central role in enabling this productivity
growth. 12
Mobile technology is used in all EU countries for citizens to contact emergency services and
recent studies show that the mobile phone has become the device most people turn to in an
emergency. 13 Text messaging is a primary means of communication in the aftermath of a
disaster, as mobile networks can generally recover within a few hours or days of a major
disaster. Aid agencies make use of text messages and mobile voice service in order to best serve
the people affected and provide information according to their needs.
Mobile network infrastructure and the adoption of mobile services are now being considered as
key indicators to European economies. The continuous evolution of mobile communications is
directly related to business activities and way of living. The greater number of consumers that
can access mobile services the more social welfare gains and benefits end users enjoy. 14
2.4 Mobile technology and network infrastructure

2.4.1 How mobile networks work
A wireless mobile communications network enables users with mobile phones to send and
receive information (voice calls, messages, data) by radio signals. A local transceiver, the base
11
GDP: Gross Domestic Product
12
http://www.gsmworld.com/digitaldivide/index.shtml
13
http://www.gsmworld.com/using/public_policy/esb/disaster_relief.shtml
14
http://www.gsmworld.com/using/public_policy/esb/research.html
station, transmits and receives radio signals to/ from the mobile phones (Figure 2.1), covering a
certain geographical area (Figure 2.2), known as the cell. Radio signals can only travel a certain
distance as they are low powered and mostly line-of-sight. Obstructions such as buildings and
hills limit the coverage that a single base station can provide. In addition, the mobile phone is a
low powered radio device and must be near a base station so that the signal has the required
power to reach the base station.
The location where the radio transceiver is installed is called a cell-site, where all the necessary
equipment like antennas, masts and associated telecommunication equipment are placed in
order to enable the communication between the mobile phone and the base station. The base
station is also connected into the mobile network and with other networks (e.g. PSTN 15 , other
mobile operators’ network).
Figures 2.1 and 2.2: Mobile Network, Base Stations & Cell coverage areas
Source: GSMA
The base station is the main part of the telecommunication equipment installed in each cell-site
and handles the necessary processing of a call. The base station controls the power transmitted
to the mobile phone and also instructs the mobile device to transmit the minimum power
required for the user to receive adequate service quality during the call.
The term “cellular” refers to the fact that in order for a wireless network to provide coverage to
many sites need to be installed in a cellular layout. This allows mobile users to travel within the
coverage area of the cellular network and receive continuous service between cells. The process
is called ‘hand-over’ and to achieve call handover without dropping the call, the coverage from
individual base stations must partially overlap. As noted above, due to the limited power that a
base-station can transmit, it can only cover a certain area depending on the characteristics of
the surrounding terrain (buildings, hills, trees, valleys etc.) and the number of simultaneous calls
that need to be served in its area. The size of a cell can vary from 100m or less to 10km or more
depending on the location and number of calls to be carried.
2.4.2 New technologies and service evolution

Cellular mobile technology has been continuously evolving for over 20 years, mainly driven by
an increasing demand for mobility and continuous communication. Across the European Union,
15
PSTN: Public Switched Telephone Network
each Member State has granted licences for 2nd Generation (2G) mobile networks. The GSM
standard is the most popular network standard for 2G mobile networks and is the one adopted
by the majority of European countries. The cross-adoption of a single standard led to multiple
benefits for mobile users as they are able to use GSM services in any country which has
deployed a GSM network. Economies of scale further help to lower the total cost of ownership
and network deployment, ultimately leading to lower tariffs, enabling more subscribers to benefit
from mobile technology.
The introduction of 3G mobile networks required access to additional radio spectrum and the
governments of each member states have procedures for the allocation of licences and radio
spectrum. While GSM networks are optimised to provide voice and low speed data (e.g. SMS)
services, 3G networks offer advanced voice services and much higher speed data and
multimedia services.
The new generation of mobile services (3G) has shown significant increase in adoption rates over
the last few years. By the end of second quarter of 2007, 8% of the total mobile connections in
Europe were 3G connections. 16 The number is forecast to double by June 2008. 3G (WCDMA
/HSPA) networks have been deployed to provide enhanced and more sophisticated services with
72 networks being already in service, 12 in deployment and 28 planned.
2.5 The need for continuous base stations deployment

Base stations are installed to provide geographic coverage and additional network capacity
where needed. Fewer are needed in less populated and rural areas, more in urban areas.
The introduction of new mobile services (e.g. 3G) requires additional, technology-specific base
stations. Operators may be required, as a condition of their licence, to install base stations
nationally to meet government or regulatory coverage targets, and they are increasingly
required to support increasing demand for concurrent calls as a base station can only carry a
certain number of calls whilst providing the required service quality.
In general, 3G networks require more base stations in order to cover the same geographical
area as the 2G networks (Figure 2.3). 3G networks in Europe currently operate at higher radio
frequencies which result in radio signals travelling shorter distances than in 2G networks.
The European Commission has agreed that the GSM 900MHz and GSM 1800MHz bands will be
approved for 3G(UMTS)900/1800 use 17 , and programmes are underway to achieve this end. If
implemented by operators, this should result in fewer base stations than would be needed
otherwise. 3G networks are deployed in the same areas where 2G networks exist and are able to
use some of the existing 2G cell-sites and facilities.
16
Source: Ovum research
17
http://www.ipex.eu/ipex/webdav/site/myjahiasite/groups/CentralSupport/public/2007-
3/COM_2007_0367/COM_COM(2007)0367_EN.pdf
Figure 2.3: Base Stations and 3G/2G cell coverage areas 18
Key
2G/3G Base Station 2G Area coverage
3G Base Station 3G Area coverage
Source: Ovum
The maximum peak power transmitted from GSM mobile phones is 2 Watt (900 ΜHz) or 1 Watt
(1800 ΜHz). In GSM networks, mobile phones do not transmit constantly, but in certain time
intervals. This technique results in a significant reduction of the average power transmitted from
the mobile phones, which does not exceed the 1/8 of the maximum values i.e. 0.25 W or 0.125
W, respectively. These values are further reduced by adaptive power control and discontinuous
transmission mechanisms. The power transmitted by GSM/3G(UMTS) mobile phones is
constantly monitored and adjusted to minimise energy consumption and improve network
quality (power transmissions beyond certain limits may result in poorer quality due to
interference issues). This base station control may result in handset power being reduced
significantly of the maximum allowed when the handset is close to the base station.
The success of cellular telephony has resulted in increasing numbers of radio base stations to
provide the capacity and geographical coverage demanded. As the deployment of more base
stations reduces the average distance between users and the nearest base station, the average
power transmitted by handsets has also been reduced. There is therefore a synergy between the
commercial requirement to extend capacity to maintain a high quality of service and a desire to
reduce the average power from handsets.
2.6 GSM Europe’s activities

GSM Europe (GSME) 19 is the European interest group of the GSM Association (GSMA) 20 , the
premier global body behind the world’s leading wireless communications standard. GSM Europe
represents around 150 operators in 50 countries/areas in Europe, serving around 600 million
subscribers. The GSMA is responsible for the development, deployment and evolution of the GSM
standard for digital wireless communications and for the promotion of the GSM family of
technologies.
18
The figure is presented for illustrative purposes only and is not scaled to show actual cell sizes
19
http://www.gsmeurope.org
20
http://www.gsmworld.com
GSM Europe is the public face of European mobile operators and the key representative forum
for the European wireless industry. It seeks to enhance and protect investments in network
infrastructure and aims to drive innovation, growth and expand consumer choice. GSM Europe
seeks to ensure that the benefits of mobile services are understood, showing how they have
enhanced the lives of citizens and brought social and economic benefits to individuals,
businesses and nations. GSM Europe will endeavour to leverage the economic interest that the
mobile industry represents in Europe.
In 2006 GSM Europe published a Health and Environment Position Statement 21 . The key
elements of this Statement are:
“In recent years, concerns have been raised about alleged adverse health effects from the
operation of mobile telecommunications technology. This is despite independent expert reports
across Europe [Stewart 22 and AGNIR 23 (UK), Zmirou 24 (France), Health Council 25 (Netherlands),
the Radiation Protection Authority 26 (Sweden), Independent Expert Committee 27 (Spain), other
major scientific reviews and advisory bodies around the world continuing to conclude that, based
on the current weight of scientific evidence, there are no known adverse health effects from
exposures below international guidelines. The reports do however recommend that research
continue.
The public’s health concerns have focused primarily on the community impact of base station
developments. The continual growth and reconfiguration of base stations are essential to extend
service coverage, enhance call quality and increase network capacity. It is often not understood
that base stations must be located near to where phones are used and, because of the limited
number of radio channels available to each operator, additional base stations must be installed
as the usage increases. In response to health concerns some local authorities and national
governments have imposed more restrictive, arbitrary, rules on the siting of mobile phone base
stations. This causes problems for operators in responding to the needs of their millions of
customers, and undermines the competitive edge that Europe has and wants to retain through
the swift uptake and development of this technology.
Policy on base station siting and related health concerns must be based on substantiated
scientific evidence and provide a framework to support GSM, 3G and future services across
Europe.
Implementing arbitrary levels that are lower than the international public exposure guidelines
[EU Council Recommendation of 12 July 1999 (Reference 1999/519/EC)] undermines the
scientific basis of current standards, creates further public confusion and increases public
concern.”
21
http://www.gsmworld.com/gsmeurope/documents/mobile_comms_matters_2006.pdf
22
UK Independent Expert Group (2000): http://www.iegmp.org.uk
23
NRPB Advisory Group on Non-Ionising Radiation (2003):
http://www.nrpb.org/publications/documents_of_nrpb/abstracts/absd14-2.htm
24
French Health General Directorate (2000): http://www.sante.gouv.fr/
25
Health Council of the Netherlands, (2004): http://www.gr.nl/pdf.php?ID=886
26
Swedish Radiation Protection Authority-SSI (2003): http://www.ssi.se/english/english_news.html
27
Independent Expert Committee (2001): htpp://www.msc.es/salud/ambiental
In 2001, GSM Europe members adopted the Recommendation on Network Rollout Good
Practice 28 aimed at encouraging dialogue and consultation with key stakeholders interested in
the deployment of mobile telecommunication networks. Key elements of the mobile
telecommunications industry recommended good practice include:
Figure 2.4: GSM Europe Good practice Recommendations
Rec. #1 Improving the dialogue with local authorities and other key stakeholders in order to
increase understanding of network infrastructure requirements and local planning
frameworks. The consultation process will take into account planning, environmental
and community issues.
Rec. #2 Considering site sharing with other radio installations or existing structures, where
technically feasible and in line with competition law and licensing conditions, when
decisions are being made on the most environmentally appropriate radio base station
solution.
Rec. #3 Sensitive siting and design, which reduces visual intrusion and can help allay public
concerns. The industry recognises that the environmental impact of radio base
station developments should be kept to a minimum.
Rec. #4 Providing information to regulatory and planning authorities on mobile

telecommunications technological developments. The industry believes that the
provision of technological information is an effective means of raising awareness and
understanding of the issues confronting the industry.
Rec. #5 Ensuring all existing and new radio base stations comply with national exposure
guidelines based on the public exposure guidelines of the International Commission
on Non-Ionizing Radiation Protection (ICNIRP), as expressed in EU Council
recommendation of 12 July 1999 (Reference 1999/519/EC) on the limitation of
exposure of the general public to electromagnetic fields (0 Hz to 300 GHz). The
industry supports exposure guidelines, such as ICNIRP, which are based on sound
scientific evidence and are subject to on-going expert review.
Rec. #6 Providing a written declaration that radio base stations are designed to comply with
national or European exposure guidelines. A signed declaration of compliance with
the relevant guidelines supports openness and provides confidence to local
communities that radio base stations are being operated safely.
Rec. #7 Implementing a clear process to respond to complaints and enquiries about radio
base stations. The industry recognises that there has often been some frustration
regarding the information provided when enquiries are received on radio base station
sites and that the quality of the information provided to the public needs to be of a
high standard.
Rec. #8 Supporting quality research programmes at the EU and Member State level based on
the WHO research agenda that will provide the basis for on-going review of
established guidelines. Expert reviews in a number of EU states have concluded that
28
http://www.gsmworld.com/gsmeurope/documents/health/recommendation_network_rollout_good_practice
.pdf
there is no convincing independent scientific research of a link between public

exposure to the low level radio signals used by mobile telecommunications systems
and adverse human health effects. However, the industry welcomes on-going,
independent, quality research programmes in order that policy can be based on
substantiated scientific evidence and criteria.
Rec. #9 Using clear and consistent supporting documentation when exchanging information
with regulatory and planning authorities. The industry recognises that it is often
confusing when presented with similar information in varying formats and therefore
documentation will aim to follow defined formats.
Source: GSM Europe

3. Implementation review of GSM Europe

Recommendations
3.1 Background
Mobile network infrastructure and the adoption of mobile services have a direct impact to
national economies and social welfare. In order to meet licensing conditions mobile operators are
required to install base stations across the country so that every user is able to benefit from the
use of mobile services.
The installation of base station facilities necessary for network deployment has increased the
public concern toward the alleged health impact of radio signals and other environmental
concerns. The mobile industry recognises that public fears should be addressed as a matter of
principle and in an open and transparent manner.
In 2001, GSM Europe and the mobile telecommunications industry in Europe adopted a self-
regulatory framework. The Recommendation on Network Rollout Good Practice 29 aimed to
encourage dialogue and consultation with key stakeholders interested in the deployment of
mobile telecommunication networks.
In 2003 the GSME Health and Environment workgroup 30 published the Implementation Report
Into good Practice Recommendations for Network Rollout to provide an overview of: the
achievement in implementation of the good practice recommendations; the effectiveness of the
good practice recommendations and to identify the remaining issues for on-going delivery of the
good practice recommendations.
As four years have elapsed since the last report was published, an updated report on the
Implementation of GSM Europe Recommendations is required.
3.2 Survey participants

The survey was addressed to all mobile operators in EU Member States (EU-27) and Switzerland
and mobile operators’ trade associations in some countries. Fifty-two (52) mobile operators and
seven (7) trade associations have participated to the survey. In 17 countries, at least two
operators have provided responses.
The map below shows GSM Europe country members. The map also presents the countries
participated in the survey.
29
http://www.gsmworld.com/gsmeurope/documents/health/recommendation_network_rollout_good_practice
.pdf
30
http://www.gsmworld.com/gsmeurope/work_groups/health.shtml
Figure 3.1: GSM Europe members and survey participants (countries)
Key
Survey Participant
No survey data available
Each one of the charts in the following sections shows the number of responses (n) for the
related survey question. For some of the questions multiple answers were possible (as indicated
in bar charts). Pie charts indicate single-response questions.
3.3 General conclusions across the EU

The main conclusions of the survey of mobile operators and trade associations are:
• There is strong support for the GSME Recommendations as shown below. The industry
recognises public concerns and takes actions to mitigate these concerns, e.g.
establishing formal processes for information provision to the public and the authorities,
implementing site sharing and using alternative designs to minimise the visual impact of
sites. The early adoption of the GSME Recommendations has served as a catalyst for
similar policies in several countries and multi-national corporate groups.
Figure 3.2: Do you have a formal company or national policy in respect of good practice
for network rollout? (Multiple responses possible)
Yes - Company 80%
Yes - National 58%
No, neither 10%
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
Source: Ovum for GSME Study (n=50)
• For 96% of the operators, processes are in place to facilitate information exchange
between the industry and key stakeholders, a group which includes the public, local
authorities, national governments and agencies, and regulatory bodies. In 41% of the
cases, these processes are a mandatory requirement. Voluntary initiatives by operators
exceed 50% of the cases.
Figure 3.3: Do you have a formal process to communicate and provide information to the
local authority/ the public on current and future network deployment plans?
Yes -
No, 4% Mandatory
requirement
, 41%
Yes -
Voluntary
(case by
case), 33%
Yes -
Voluntary,
always
used, 23%
• GSM Europe members continue to support independent research programs at EU and

member state level. All operators contribute to GSMA programmes.
• The approach to implementing the GSME recommendations varies between countries for
a number of reasons:
o the operator’s network rollout policy may need to comply with national
regulatory requirements or a national policy for network rollout good practice.
National policies do however largely reflect GSM Europe Recommendations
o the level of public concern about EMF issues may be influenced by particular
interest groups and the media. Operators’ actions to communicate with the
public and other stakeholders will be influenced by the level of public concern,
and therefore vary between countries. There are cases where the industry is
proactive and operators follow policies similar to GSM Europe Recommendations
in markets with moderate or low levels of concern
o companies with multi-national operations may have network rollout guidelines

and policies which are followed by all group members
o a national trade association may coordinate national activity and help facilitate
EMF-related information flow to the local authorities and other key stakeholders.
They also help to handle enquiries from the public with industry-wide
coordination
o the requirements provided by national governments and agencies, and their

advice to the public vary, (e.g. additional precautionary measures) resulting in
different needs for communications by the operator. Operators' experience and
research indicates that such measures increase public concern 31
• Public concern is mainly expressed as related to possible health issues; environmental

and aesthetic concerns appear to be at a lower level with technology issues being of
least or no concern. Operators report that significant complaints/ enquiries appear from
only 7% of the sites which may suggest that complaints are primarily local. The following
two figures show that in the great majority of the cases public concern remains stable
over the last 18-24 months, across the various types of complaints.
Figure 3.4: Trends in the level of concern the public has in each complaint category
Increased Decreased No change
Health 39% 8% 53%
Environment 28% 5% 67%
Aesthetic 19% 6% 75%
Technology 3% 14% 83%
Other 33% 0% 67%
Source: Ovum for GSME Study, as reported from operators’ customers (n=39)
31
Wiedemann et al, (2006). The Impacts of Precautionary Measures and the Disclosure of Scientific
Uncertainty on EMF Risk Perception and Trust. Journal of Risk Research, 9(4), pp. 361 - 372.
The level of the “Other” category in the Figure above is mainly driven from concerns
over potential impacts on property price due to installations of base stations in an area.
Figure 3.5: What is the trend in the overall level of complaints/ concerns/ enquiries
related to network rollout, over the last 18-24 months?
Increasing,
Decreasing,
32%
6%
Remaining
about the
same, 62%
Source: Ovum for GSME Study, as reported from operators’ customers (n=47)
Figure 3.6: What effect do you think your activities related to GSM Europe
Recommendations have had on complaints/ enquiries?
Increased,
7%
Decreased,
32%
No change,
61%
• As shown in the previous two charts, there is no evidence for a general increase in public
concern in the surveyed countries; 68% respond that the level of concern remained
about the same over the last 18 to 24 months or actually decreased. 32% of operators
responded that public concern, based on their experience, has increased during this
period.
• 93% of operators state that their activities related to GSM Europe Recommendations
have contributed to keep the level of complaints and enquiries stable or even decreased
them. This result may suggest that GSM Europe Recommendations is a communication
and implementation tool which when utilised by the industry may control or lower public
concerns.
3.4 The impact of GSM Europe Recommendations

The paragraphs below present the survey findings regarding each one of the GSM Europe
Recommendations. Key elements of the mobile telecommunications industry recommended good
practice are presented at the beginning of each of the following paragraphs:
Recommendations 1 & 9
Improving the dialogue with local authorities and other key stakeholders in order to increase
understanding of network infrastructure requirements and local planning frameworks. The
consultation process will take into account planning, environmental and community issues.
Using clear and consistent supporting documentation when exchanging information with
regulatory and planning authorities. The industry recognises that it is often confusing when
presented with similar information in varying formats and therefore documentation will aim to
follow defined formats.
Operators use various methods to inform key stakeholders, primarily local authorities, public or
local communities and the regulator. Other interest groups include media, health agencies, other
mobile operators, landlords, politicians and key-opinion leaders.
Figure 3.7: Who are the main stakeholders in information provision processes? (Multiple
responses possible)
Local authority 88%
Public/ local community 69%
Regulator 61%
Other 35%
Not applicable 4%
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Figure 3.8: How do you facilitate the information flow? (Multiple responses possible)
Information session/
65%
road show
One to one sessions 63%
Conduct consultation
50%
process
Seminars 40%
Letters to nearby
38%
residents
Public/ media
announcement 35%
Other 33%
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
Other means, apart from the ones shown in the chart below, include on-line consultation tools,
brochures for the public and employees, EMF portals, general PR activities and public
engagement programmes. A general technique is not able to satisfy different stakeholder’s
requirements and address all the different issues. Operators therefore use many methods to
meet stakeholders’ requirements as indicated in the chart above.
To satisfy the interests of stakeholders, operators emphasize technology and health related
information in their communications. 81% of the survey participants provide both types of
information.
Figure 3.9: What type of information is provided? (Multiple responses possible)
Technology 85%
Health information 81%
Potential impact on environment 73%
Description of the proposed site including

63%
computer generated images or photo montages
Planning framew ork 60%
Potential impact/ benefit to community 52%
Other 21%
0% 20% 40% 60% 80% 100%

This information is mainly provided by the operator when there is a new deployment and when it
is requested, but also in annual reports. A varying format depending on project and persons
involved is used in half of the cases.
Figure 3.10: How frequently do you provide information to local authorities or other regulatory
body? (Multiple responses possible)
Only when there is new deployment 69%
Only when requested by public/ local authority 57%
Annual report 31%
Other 23%
Quarterly report 4%
Monthly report 2%
0% 20% 40% 60% 80% 100%
Around 40% of the respondents have auditing processes in place in order to assess the
effectiveness of the information exchange. For 23% of respondents the audit process is
voluntary and for 15% it is a mandatory requirement. For more than 60% of respondents there
is no reporting on the effectiveness of information exchange activities and this is an area for
potential increased attention.
The survey indicates that operators proactively inform the public about their requirements to
install more antennas and sites categorisation. In over 75% and 60% of the cases respectively,
this is part of a voluntary programme.
Figure 3.11: Have you communicated the need to install more network antennas to the public?
No, 2% Yes -
Yes - Mandatory,
Voluntary 23%
(case by
case), 49%
Yes -
Voluntary,
always used,
27%

Figure 3.12: Do you conduct a consultation programme or involve local communities in the
categorisation of the sites 32 ?
Yes -
Y es - Voluntary,
Mandatory, always used,
18% 18%
No, 20%
Yes -
Voluntary
(case by
case), 43%
Recommendation 2
Considering site sharing with other radio installations or existing structures, where technically
feasible and in line with competition law and licensing conditions, when decisions are being
made on the most environmentally appropriate radio base station solution.
All operators share infrastructure for base stations, with more than 5 types of infrastructure
being shared on average by an operator. Details are shown in the following figure.
Figure 3.13: With what types of infrastructure do you have site sharing? (Multiple responses
possible)
Tower site sharing 98%

Other telecommunication masts 92%
Roof-mounted site sharing 88%
Other operator's facilities 77%
Other radio installations 56%
A utility's facilities 52%
Antennas 42%
Transmission Equipment Shelters 44%
Other 15%
0% 20% 40% 60% 80% 100%
32
Site categorisation is used in some countries to assess the level of consultation required. It is not a
measure of whether a site should or should not be progressed.
The survey results show that 83% of 3G operators (with 2G operations) share sites with their
current 2G facilities/sites and 45% of these operators share between 90% and 100% of their 3G
sites with 2G sites. On average, 81% of 3G sites are shared with 2G sites.
Site sharing is implemented with established processes. These processes enhance cooperation
between operators, reduce time requirements and increase the effectiveness of site sharing
procedures. 85% of survey respondents have formal processes for site sharing.
All operators expect to maintain or increase (78% of operators) their site sharing over the next 5
years.
Operators report that landscape preservation (74% of operators) and environmental concerns
(73% of operators) are very important/ important considerations for site sharing. For 89% of
operators, cost saving is the most important reason for the increasing trend in site sharing. In
many cases, site sharing is implemented by operators as a requirement by local authorities,
licensing conditions or national competition laws.
Figure 3.14: Reasons and degree of importance for site sharing
Very
important/ Not Not
Important Neutral important Applicable
Cost saving 89% 9% 0% 2%
Landscape preservation 74% 19% 5% 2%
Environmental concern 73% 23% 2% 2%
Required by local authority 70% 16% 2% 11%
Required by licensing conditions 20% 25% 7% 48%
Required by competion law 14% 19% 12% 55%

Recommendation 3
Sensitive siting and design, which reduces visual intrusion and can help allay public concerns.
The industry recognises that the environmental impact of radio base station developments
should be kept to a minimum.
The use of alternative design and installations to reduce the visual impact of sites is a key
element of operators’ network rollout policies and the great majority of operators (94%) use
such techniques.
Examples include chimneys, artificial trees, advertising signs, architectural building features,
church windows, inside church towers, grain silos and antenna painted to match a building
facade.
Figure 3.15: Examples of alternative design
Artificial tree Street sign encloses Building feature

In building integrated design
design microcell antenna encloses antenna
Source: Operators, Ovum for GSME Study
Camouflaged design is generally implemented only if required by authorities (e.g. listed

buildings) as the public may accuse operators of “hiding” antennas to lower health concerns. It is
important to note that some installations, e.g., camouflaged trees may be significantly more
expensive than conventional masts. In 40% of the cases, the integration of antennas with
existing landscape and infrastructure is implemented following specific design guidelines (per
operator or national).
In general, there are planning exemptions for antenna sizes or power emissions.
Recommendation 4
Providing information to regulatory and planning authorities on mobile telecommunications

technological developments. The industry believes that the provision of technological
information is an effective means of raising awareness and understanding of the issues
confronting the industry.
Operators provide a range of technology related information to interested parties. In 80% of the
cases operators provide detailed information not only about the technology that mobile services
are using and the evolution of mobile communications, but also an assessment of the potential
impact and benefits to the community. The following figure summarises the information provided
by the operators to regulatory and planning authorities.
Figure 3.16: What kind of information do you provide to regulatory and planning authorities on
mobile telecommunications technological developments? (Multiple responses possible)
Information on new services /technologies, description

80%
of services, benefits, possible impact
Information on exisitng services /technologies,

80%
description of services, benefits, possible impact
Possible infrastructure requirements 66%
Information on public consultation 43%
Timescales of development 41%
Other 5%
0% 20% 40% 60% 80% 100%
85% of operators hold educational sessions with local authorities to explain how the technology
works or to provide information on why particular sites locations are selected.
The feedback from interested parties is positive in the main and sessions are well appreciated. In
the great majority of the cases, local authorities find the interaction informative. Very rarely it
has a negative impact.
These sessions are held at varying intervals. In most cases regulatory and planning authorities
are contacted as needed to discuss specific cases (e.g. when there is a new development).
Figure 3.17: How often do you hold educational sessions? (Multiple responses possible)
Other intervals or on a
93%
case by case basis
Annualy 7%
Quarterly 5%
0% 20% 40% 60% 80% 100%

More than half of the operators have started discussions and consultations for deploying 3G
networks using lower frequencies (900 MHz). Such implementation should result in a reduced
number of base stations required, particularly in rural areas, to cover a certain geographical area
with 3G services, compared with the current 3G deployments in higher frequencies.
Recommendation 5
Ensuring all existing and new radio base stations comply with national exposure guidelines
based on the public exposure guidelines of the International Commission on Non-Ionizing
Radiation Protection (ICNIRP), as expressed in EU Council recommendation of 12 July 1999
(Reference 1999/519/EC) on the limitation of exposure of the general public to
electromagnetic fields (0 Hz to 300 GHz). The industry supports exposure guidelines, such as
ICNIRP, which are based on sound scientific evidence and are subject to on-going expert
review.
All operators report that existing and new base stations comply with national, European or
international (ICNIRP 33 ) limits. Some national exposure limits tend to be stricter than the EU
Council Recommendation and ICNIRP guidelines. Detailed information can be found in Annex I of
the report, where RF exposure limits for each country are presented.
Figure 3.18: What kind of public EMF 34 exposure guidelines do existing and new radio base
stations comply with? (Multiple responses possible)
National exposure
85%
guideline
European exposure
67%
guideline
International exposure
63%
guideline
Others 29%
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
Recommendation 6
Providing a written declaration that radio base stations are designed to comply with national or
European exposure guidelines. A signed declaration of compliance with the relevant guidelines
supports openness and provides confidence to local communities that radio base stations are
being operated safely.
33
ICNIRP: International Commission on Non-Ionizing Radiation Protection (http://www.icnirp.de)
34
EMF: Electro-Magnetic Field
Many operators (73%) report that 100% of their operational sites are certified and a written
declaration is available. 79% of the operators report to have more than 90% certified sites. Sites
are certified by an official governmental agency, the regulator or through an industry self-
certification process. All certifications are referred to exposure limits that the operator’s country
has adopted.
Figure 3.19: What percentage of your sites is certified?
100%
Number of operators (%)
79%
80%
60%
40%
20%
7%
0% 0% 2% 2% 2% 2% 2% 2%
0%
< 10% 11 - 20% 21 - 30% 31 - 40% 41 - 50% 51 - 60% 61 - 70% 71 - 80% 81 - 90% > 91%
% of certified sites
In almost all of the cases (96%), operators report that they have policies for their own
employees when they are accessing areas close to antennas. Guidelines for third parties e.g.
painters or construction workers working in or around the antennas are provided in 83% of the
cases. Such measures include safety distances, use of radio frequency hazard monitors and
power shut down procedures.
All operators perform pre-installation measurements or pre-installation calculations prior to

commissioning a site. Other operators perform also post-installation RF exposure measurements.
Figure 3.20: Which of the following do you have to do to commission of a new site? (Multiple
responses possible)
Pre-installation
75%
calculations
Post-installation
58%
measurements
Other 47%
Pre-installation
23%
measurements
Regular repeat
21%
measurements
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

The main reason for in situ (local) site measurements is to respond to specific concerns of the
public or others. This is clearly shown in the following chart.
Figure 3.21: For which of the following reasons do you measure sites? (Multiple responses
possible)
In response to public or other concerns (including

92%
spot measurements)
A requirement of the regulatory authorities 42%
It is part of the company's communication policy 33%
Other 13%
0% 20% 40% 60% 80% 100%
Recommendation 7
Implementing a clear process to respond to complaints and enquiries about radio base
stations. The industry recognises that there has often been some frustration regarding the
information provided when enquiries are received on radio base station sites and that the
quality of the information provided to the public needs to be of a high standard.
Operators take special care of complaints and enquiries about base station planning and EMF
issues. Almost all operators (98%) responded that processes have been established to address
individual issues (e.g. consumer or site-specific). A high percentage of operators address EMF
complaints and enquiries at a national level or through a national trade association (where such
an association exists).
Figure 3.22: What processes do you have in place for handling complaints and enquiries about
base station planning and EMF issues? (Multiple responses possible)
To address individual
issues (e.g. consumer 98%
or site-specific)
To address issues
raised to the company 68%
at national level
To address issues
through a national 55%
Trade Association
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

In most cases, the liaison processes with local residents and authorities are managed by
specialist staff or named contact personnel. Other methods have also been implemented as
shown in the figure below, with the most common one being telephone hotlines and web-sites
that receive enquiries and dispatch information.
Figure 3.23: What are the methods used to manage complaints and enquiries? (Multiple
responses possible)
Named contact personnel for liaison with local

authorities 78%
Employment of specialist staff for communication/ issue

78%
management purposes with local residents
Telephone hotlines and web-sites that receive enquiries

65%
and dispatch information
Established Trade Association representing network

operators and providing coordination of information 61%
exchange
Established processes in the handling of enquiries with

61%
specified response time
Other 9%
0% 20% 40% 60% 80% 100%
Recommendation 8
Supporting quality research programmes at the EU and Member State level based on the WHO
research agenda that will provide the basis for on-going review of established guidelines.
Expert reviews in a number of EU states have concluded that there is no convincing
independent scientific research of a link between public exposure to the low level radio signals
used by mobile telecommunications systems and adverse human health effects. However, the
industry welcomes on-going, independent, quality research programmes in order that policy
can be based on substantiated scientific evidence and criteria.
The industry actively supports independent research programmes in the areas of mobile
technologies, health, environment and social concerns. More than 80% of the operators state
that they participate in research programmes. These include GSMA programmes 35 and
initiatives, national studies (either in a government or corporate level) and international studies.
Indicative areas that these projects address are: in vitro studies on biological effects,
epidemiology, dosimetry and field simulations, risk communication and risk evaluation, proximity
of base stations and alleged health hazards, children issues, body implants, cognitive issues,
blood circulation, ear-balance function, and others.
Figure 3.24: In which of the following types of research studies do you participate? (Multiple
responses possible)
Support national
government funded 58%
research
Individual company
research (group-wide) 44%
corporate
Other 24%
Individual company
research (local/ 11%
national)
0% 10% 20% 30% 40% 50% 60% 70%
It is a common policy across the operators’ community to make the outcomes of their research
studies available to the public, regulatory and local authorities in order that general awareness
can be raised. The results are published in the scientific literature and communicated in seminars
and industry meetings, through portals, press releases, brochures and communication letters.
3.5 General conclusions

The following section outlines a number of conclusions derived from the analysis of the survey
data and operators’ responses. The aim of the conclusions is to propel processes and procedures
and increase the effectiveness of operators’ actions.
1. It is crucial for the mobile industry to closely monitor and audit these processes in order
to be regularly reassured that informative programmes and other initiatives have the
results anticipated by the industry. It is reported that despite operators’ efforts and
actions, public and local authorities are not always receptive to accept the points
presented in these programmes due to lack of trust in the accuracy of and credibility in
35
All GSMA members contribute to the budget that supports the GSMA funded research programme. The
80% response rate indicates that not all respondents are aware of this fact and suggests the need for
additional communication towards GSMA members.
the information provided. Governments on national, regional and local level therefore
play a role in trusted and science-based communications. It is important that trust in
these communications is established with the recipients.
2. Risk communication activities must address public concern. The industry is working to
provide community-specific information (e.g. to discuss particular base station
deployments and the benefits to the community where the deployment takes place) and
to help address local concerns through frequent interaction with interested stakeholders.
The level activity should be proportional to the level of public concern.
3. It is important that national research programmes include open publication of the

outcomes of such studies as part of the information exchange processes. The conclusions
of these studies may also be used to inform government and operator EMF policies.
There is a need for better communication by governments to interested stakeholders of
the results and their interpretation. To avoid unnecessary duplication by national
research programmes, it is recommended that these are based on the WHO 36 research
agenda and are co-ordinate at international and EU levels.
4. It is reported that public concern increases during early phase of network rollout and
when there is media coverage (e.g. newspaper articles etc.) claiming unsubstantiated
health risks. The involvement of national governments with specialised communication
programmes and in conjunction with the mobile industry can help facilitate public access
to updated information regarding EMF developments. Such programmes should be
targeted to address local issues and match the level of concern in that country. They
should be designed to fill the communication gap, minimise unnecessary concerns and
ambiguous messages, and build the confidence of public and local communities.
36
World Health Organization, International EMF Project (www.who.int/peh-emf/)
38
4. Research support
4.1 Background
The use of mobile phones has increased substantially in recent years. This has been paralleled
by concern about possible effects on health due to exposure to the electromagnetic fields
produced by the phones and base stations. A recent survey 37 conducted by the European
Commission shows varying levels of concerns among European citizens of different Member
States, regarding potential health risks from the operation of mobile technologies. Overall the
survey indicates that Europeans are divided in their concerns about the potential health risks of
EMF: 14 % not at all concerned, 35% not very concerned, 35% fairly concerned and 13% very
concerned. The citizens feel also that national public authorities could do more in regard to
potential health risks of EMF and communication with the public. 38 The survey also reported that
mobile communications masts are one of main sources of concern about electromagnetic field
exposures but that EMF rates overall low in comparison to other environmental agents.
4.2 Current status: European Commission - EU

The European Commission (EC) actively supports initiatives which monitor the potential health
effects of EMF. These actions include the funding of research, publishing information and
contributing to the establishment of a legal framework for the protection of workers and citizens.
At EU level, the Council Recommendation of 12 July 1999 (1999/519/EC) 39 , which limits the
exposure of the general public to electromagnetic fields (0 Hz - 300 GHz) establishes a
framework of minimum restrictions and reference levels. The Recommendation is based on the
guidelines 40 of the International Commission on Non Ionizing Radiation Protection (ICNIRP) 41 as
endorsed by the Scientific Steering Committee advising the European Commission in 1998 42 , the
Scientific Committee on Toxicity, Ecotoxicity and the Environment (CSTEE) in 2001 43 and further
confirmed in the recent opinion of the Scientific Committee on Emerging and Newly Identified
Health Risks (SCENIHR) on 29 March 2007 44 . In relation to radiofrequency fields the SCENIHR
opinion states:
“Since the adoption of the 2001 opinion extensive research has been conducted regarding
possible health effects of exposure to low intensity RF fields, including epidemiologic, in vivo,
and in vitro research. In conclusion, no health effect has been consistently demonstrated at
exposure levels below the limits of ICNIRP (International Committee on Non Ionising Radiation
37
http://ec.europa.eu/public_opinion/archives/ebs/ebs_272a_en.pdf
38
http://ec.europa.eu/health/ph_determinants/environment/EMF/emf_en.htm
39
http://ec.europa.eu/enterprise/electr_equipment/lv/rec519.pdf
40
http://www.icnirp.de/documents/emfgdl.pdf
41
http://www.icnirp.de
42
http://ec.europa.eu/food/fs/sc/ssc/out19_en.html
43
http://ec.europa.eu/health/ph_risk/committees/sct/documents/out128_en.pdf
44
http://ec.europa.eu/health/ph_risk/committees/04_scenihr/docs/scenihr_o_007.pdf
.
39
Protection) established in 1998. However, the data base for evaluation remains limited
especially for long-term low-level exposure.”
On the basis of this conclusion, the SCENIHR makes a number of recommendations for further
research. It is the task of the authorities in Member States to ensure that adequate health
protection measures are in place. When reference levels are exceeded, it is recommended that
national authorities carry out an assessment of the exposure situation and take appropriate
follow-up actions, such as informing the public, exposed changes in the installation or design of
the source of radiation or in the way it is operated 45 . The Commission prepared a report on the
implementation of the Council Recommendation for public exposures in 2002 and will provide a
report update in 2008.
Further EC legislation includes the Directive on radio and telecommunications terminal

equipment (1999/5/EC) 46 and worker safety (2004/40/EC) 47 , which is known as the Physical
Agents (EMF) Directive. The European Union adopted the Physical Agents (EMF) Directive to
limit occupational exposure to electromagnetic fields from all sources. It is applicable to all
employers in the EU and it must be incorporated into domestic laws across EU by 30th April
2008. The Directive states:
• a risk assessment is required for each employer
• the employer assumes responsibility for employees’ health and safety
• appropriate training and relevant information shall be provided to the employees by the
employer
• The employee is entitled to a medical examination, in cases where over exposure is

identified.
One current major activity is an EC funded project, EMF-NET, which will review the body of
existing research in order to provide clear summary information to policy makers regarding
public and worker exposures to electromagnetic fields. 48 The parties involved in the study
include representatives of all the major research groupings in Europe, public health agencies and
industry stakeholders such as GSMA.
The following table provides a summary of some of the major global research programmes
related to EMF issues based on data collected by the GSMA 49 .
45
Source: European Commission (EC),
http://europa.eu.int/comm/health/ph_determinants/environment/EMF/emf_en.htm
46
http://ec.europa.eu/enterprise/rtte/dir99-5.htm
47
Source: European Commission (EC), http://europa.eu.int/eur-
lex/pri/en/oj/dat/2004/l_159/l_15920040430en00010026.pdf
48
http://web.jrc.ec.europa.eu/emf-net/
49
http://www.gsmworld.com/health/programs/index.shtml
.
40
Figure 4.1: Major Health Research Programmes Related to EMF issues
Program Start End Budget Scope
(€Million)
Biological, epidemiological and dosimetry studies.
Australia 2004 2009 €1.6
Public information dissemination also a high priority.
Epidemiological and biological studies, reproduction,

Denmark 2004 2008 €4.0
risk perception and human provocation studies.
Epidemiological, biological and cellular studies of cancer

European 2004 2007 €11.5a
and non-cancer endpoints. Policy advice and science
Commission
evaluations.
Biological studies, possible effects on children and

Finland 2004 2007 €1.5b
passive metallic human implants.
Epidemiological studies of children, assessment of new

France 2007 2012 €1.8c
technologies and risk communication.
Mechanisms of action, effects on animals and humans,

Germany 2002 2008 €17.0d
determination of the exposure and risk communication.
Epidemiological, biological and cellular studies of cancer

GSM 2000 On- €10.0 e
and non-cancer endpoints. Technology and standards
Association going
evolution, risk perception.
Sociological and epidemiological research, biological

Netherlands 2006 2014 €16.6
studies and technological exposure assessments.
Exposure assessment, human epidemiological and

Switzerland 2007 2011 €5.0
experimental studies, cellular biology and risk
communication.
Effects on brain function, exposure to pulsed signals,

United Kingdom 2001 2007 €10.1f
cellular changes psychological and sociological studies,
epidemiology and human volunteer studies.
Series of studies designed to characterize the toxicity

USA 2007 2011 €15.5
and potential carcinogenicity of long-term exposure to
the RF energy.
Notes: Except where noted, all funds are from government sources. Currency conversions at prevailing
exchange rates.
a
additional funds from national authorities and industry for some projects.
b
60 % Finnish Government)
c
50 % state-funded and 50 % industry founding members.
d
equally shared by government and the network operators.
e
additional funds from national authorities and other industry for some projects.
f
funds from both government and industry.
Source: GSM Association (2007) 50
4.3 The involvement of GSM Europe and GSMA
50
http://www.gsmworld.com/health/programs/index.shtml
.
41
The GSMA in partnership with the Mobile Manufacturers Forum (MMF) and various national
authorities commenced a research programme in 2000 to address WHO identified research
priorities. The studies are reported in the open peer-reviewed scientific literature and the
outputs will contribute to the planned WHO health risk assessments of radiofrequency (RF)
fields.
A key requirement for the GSMA of supporting research has been to ensure that the researchers
are responsible for the scientific integrity of the studies with a requirement for open publication
of the findings. For many studies the GSMA contributes partial funding in partnership with public
health agencies and upon the recommendation of independent experts who monitor the
scientific progress. These mechanisms provide milestone and budget accountability without
compromising the scientific independence of the research. All biological studies are subject to
the ethics procedures of the research institution. 51 . The WHO database 52 indicates that there are
28 projects in which GSMA acts as a funding agency. The majority (25) of these studies are
related to mobile signals. Further information on GSMA supported research studies can be found
at the GSMA’s web site 53 .
4.4 International Research

4.4.1 World Health Organization
WHO initiatives
The WHO, through the International EMF Project (setup in 1996) 54 , has established a
programme to monitor the EMF scientific literature: to evaluate the health effects from exposure
to EMF; to provide advice about possible EMF hazards and to identify suitable mitigation
measures. Following extensive international reviews, the International EMF Project has
promoted research to fill gaps in knowledge. In response national governments and research
institutes have funded over $250 million of EMF research over the past 10 years. By June 2007,
the WHO International EMF Project included 678 studies related to mobile phone signals.
Extensive research has been conducted into possible health effects of exposure to many parts of
the frequency spectrum. This survey shows that the mobile industry is a significant contributor
to national and international research programs. The consensus of all reviews conducted so far
indicates that exposures below the limits recommended in the International Commission on Non-
Ionizing Radiation Protection (ICNIRP, 1998) EMF guidelines, covering the full frequency range
from 0 - 300 GHz, do not produce any known adverse health effects. However, there are gaps in
knowledge that still need to be filled in order that better health risk assessments can be made.
The International Agency for Research on Cancer (IARC), a specialised WHO agency, is intending
to conduct a review of cancer risk from RF fields in 2008-2009 and the International EMF Project
51
Source: GSMA
52
http://www.who.int/peh-emf/research/database/emfstudies/
53
http://www.gsmworld.com/health/programs/gsmaresearch.shtml
54
http://www.who.int/peh-emf/research/database/emfstudies/
.
42
will undertake an overall health risk assessment for RF fields in 2009-2010. 55
Protection standards
International exposure guidelines have been developed to provide protection against established
effects from RF fields by the International Commission on Non-Ionizing Radiation Protection
(ICNIRP, 1998) 56 and the Institute of Electrical and Electronic Engineers (IEEE, 2005). The
ICNIRP guidelines form the basis for European recommendations and directives and are widely
used around the world. 57
WHO conclusions
WHO concludes that while no adverse health effects are expected from exposure to RF fields
from base stations and wireless networks, research is still being promoted by WHO to determine
whether there are any possible health consequences from the higher RF exposures from mobile
phones. Specifically for wireless networks the WHO states:
“Considering the very low exposure levels and research results collected to date, there is no
convincing scientific evidence that the weak RF signals from base stations and wireless networks
cause adverse health effects.” 58
4.4.2 Precautionary policies

As more research data becomes available, the likelihood that exposure to electromagnetic fields
constitutes a serious health hazard reduces; nevertheless, some uncertainty remains. The public
debate over electromagnetic fields focuses on the potential detriments of electromagnetic fields
but often ignores the benefits associated with electromagnetic field technology.
Since there are still gaps in knowledge, continued research and better analysis of health risks is
needed. Moreover, without scientifically recognised adverse effects on health, it is not possible
to produce evidence-based recommendations. Therefore, the WHO states 59 :
“One of the objectives of the International EMF Project is to help national authorities weigh the
benefits of using electromagnetic field technologies against the possibility that a health risk
might be discovered. Furthermore, the WHO will issue recommendations on protective
measures, if they may be needed. It will take some years for the required research to be
completed, evaluated and published. In the meantime, the World Health Organization has issued
a series of recommendations:
• Strict adherence to existing national or international safety standards: such standards,

based on current knowledge, are developed to protect everyone in the population with a
large safety factor.
• Simple protective measures: barriers around strong electromagnetic field sources help
55
http://www.gsmworld.com/health/programs/sciencemilestones.shtml
56
http://www.icnirp.org/documents/emfgdl.pdf
57
http://www.who.int/docstore/peh-emf/EMFStandards/who-0102/Worldmap5.htm
58
Source: WHO (2006) – Fact Sheet No 304
59
http://www.who.int/peh-emf/about/WhatisEMF/en/index5.html
.
43
preclude unauthorized access to areas where exposure limits may be exceeded.
• Consultation with local authorities and the public in siting new power lines or mobile
phone base stations: siting decisions are often required to take into account aesthetics
and public sensitivities. Open communication during the planning stages can help create
public understanding and greater acceptance of a new facility.
• Communication: an effective system of health information and communication among

scientists, governments, industry and the public can help raise general awareness of
programmes dealing with exposure to electromagnetic fields and reduce any mistrust
and fears.”
4.4.3 Other reports

Other recent expert reviews and independent reports are presented in the figure below and a
much longer list is available from the GSMA website 60 .
60
http://www.gsmworld.com/health/links/independent.shtml
.
44
Figure 4.2: Indicative list of recent expert reviews and independent reports
Funding Source Title Year of Link

completion
Mobile Telecommunications & 2007 http://www.mthr.org.uk/documents/MTH

Health Research Programme R_report_2007.pdf
SCENIHR report Possible effects of 21 March http://ec.europa.eu/health/ph_risk/com

Electromagnetic 2007 mittees/04_scenihr/scenihr_opinions_en.
Fields (EMF) on htm
Human Health,
Scientific Committee
on Emerging and
Newly Identified
Health Risks
(SCENIHR),
Swiss Research Foundation 2007 http://www.mobile-

on Mobile research.ethz.ch/var/jb2006.pdf
Swedish Radiation Protection 2007 http:www.ssi.se/ssi_rapporter/pdf/ssi_ra

Authority’s Independent pp_2007_4.pdf
Expert Group
Health Council of the Research on UMTS 2007 http://www.healthcouncil.nl/pdf.php?ID=

Netherlands Electromagnetic and DETC systems 1505&p=1
Fields
Institute of Engineering and Position Statement 2006 http://www.theiet.org/publicaffairs/bepa

Technology on the Possible g/POSTAT02final.pdf
Health Effects of
Mobile Phones and
Electricity
Distribution
Rapport du groupe d’experts, Téléphonie mobile et April 2005 http://www.sante.gouv.fr/htm/dossiers/t

l'Agence Française de santé elephon_mobil/rapports.htm.
Sécurité Sanitaire
Environnementale
Royal Society of Canada’s Potential health risks 2004 http://www.rsc.ca/files/publications/expe

(RSC) Expert Panel of radio frequency rt_panels/RF//expert_panel_radiofrequen
fields from wireless cy_update2.pdf
telecommunication
devices
Source: Ovum, GSMA, Trade Associations’ websites
.
45
Annex I - Country profiles

The following section summarises the findings of the survey. For each EU country (including
Switzerland) two sections are included:
• the first section provides an overview of the actions taken by GSM Europe members
towards the implementation of GSME Recommendations for Network Rollout (see
Section 2.6 or Annex III)
• the second section provides a summary of: the level of public concern for network
rollouts 61 ; codes of practice and audit processes, voluntary actions from MNOs (over and
above GSME Recommendations); government actions; and the exposure guidelines
followed in each country.
Data collection
The collection of the data was facilitated via an on-line survey tool. Ovum Consulting, in
conjunction with GSM Europe, developed a questionnaire of 70 questions. The objectives were to
gather information, with supporting commentary and background evidence on actions taken by
GSM Europe members for the implementation of GSM Europe Recommendations for Network
Rollout, together with additional data on other governmental or national actions. Data regarding
Base Station Planning Procedures applicable to each country were also gathered. Participants
were able to provide open-response answers (text based) and attachments where applicable, in
order to address specific issues in their respective markets in more detail. The survey was
undertaken during August-September 2007.
The structure and quality of the data gathered were based on receiving relevant, updated and
accurate data from GSM Europe members. The information provided was sourced from each
GSM Europe member related to:
• national and company network rollout policies, implementation and frequency of consultation
programmes and information provision procedures
• policies of regulatory/government authorities
• monitoring and internal auditing processes, management and processes of handling public
complaints/ enquiries
• information on the level and categorization of public concern
• data on site sharing and use of environmentally friendly base station design techniques;
data on base station compliance
• national RF exposure legislation and guidelines
• support of scientific, national and international, research; and other data affecting
implementation.
61
The level of public concern of this survey is according to the number and type of complaints/ enquiries
mobile operators receive from their customers.
.
46
I.1 Austria
I.1.1 Implementation of GSME Recommendations
Rec.#1 & 9 Austrian operators have formal processes in place to communicate information to the
local authority/ the public on current and future network deployment plans. The
operators also: communicates the need to install more network antennas to the public;
provide detailed technical and supporting deployment justifications with each application
to the local authority or other regulatory body; have a consultation programme or
involvement with local communities regarding the categorisation of proposed sites; hold
information sessions/ road shows and one to one sessions with stakeholders. Twice a
year (or when there is a new development/ request from the public) and for each new
base station the operators provide a brochure on health and technology issues and a
standard technical information sheet. The “Dialogue Handbook Mobile Communication” 62
brochure is provided regularly to communities and the operators have implemented a
monitoring and documentation system to help manage the information exchange
process, the results of which are published. The Austrian trade association (Forum
Mobilkommunication, FMK) has conducted a survey concerning the Agreement
concluded with the Association of Austrian Local Authorities.
Rec. #2 Operators reported that they share infrastructure with other operators’ facilities: tower
sites; roof-mounted sites; other telecommunication masts and utilities’ facilities. The
percentage of shared sites has reached 50% and 75% of 3G sites are shared with 2G
sites. Cost saving and environmental concerns are the main reasons for site sharing.
Rec. #3 Operators make use of alternative designs to minimise the visual impact of sites, e.g.
artificial chimneys, artificial church windows, advertising signs, “designed” masts (e.g.
from stainless steel). It is important to note that “artificial tree” designs are not well
accepted by local authorities or the public. Camouflaged design is implemented only if
required by authorities (e.g. listed buildings), since there are cases where the public has
accused operators of “hiding” antennas to lower health concerns.
Rec. #4 Educational sessions have been held to explain to the local authorities how technology
works and the reasons for sites to be established in specific locations. These sessions
are well received by the audience (e.g. city council members). One operator reported
that it is considering the deployment of a 3G network operating at a lower frequency
ranges which will allow the reduction of the total number of sites required.
Rec. #5 All operators reported base station compliance with European exposure guidelines.
Rec. #6 100% of operators' sites are certified and there are processes to ensure compliance with
the EU Directive recommendations for occupational exposures. Companies have policies
for its own employees when accessing areas close to antennas and provide guidelines
for third parties e.g. painters or construction workers working in or around antennas.
Monitoring and measuring the RF exposure in public areas is performed on a case by
case basis in response to public concerns.
62
http://www.la-umwelt.de/Dialoghandbuch_Mobilfunk.pdf
.
47
Rec. #7 Operators have procedures at three levels: to address issues raised at the national
level; to address issues through the FMK and to address individual issues (e.g.
consumer or site-specific). Concerns and enquiries are handled by specialist
communications staff managing issues with local residents. There are named contact
personnel for liaison with local authorities. Telephone hotlines and websites are used to
receive enquiries and dispatch information and the FMK (representing all network
operators) coordinates the exchange of information. The response times of these
procedures are monitored.
Rec. #8 The operators support national studies and GSMA programmes and initiatives, the
results from which are disseminated by the FMK through press releases - to advertise
results, promote public awareness and inform authorities.
I.1.2 Country overview

Level of It is reported that the high level of concern (for health, aesthetic and technology
concern matters) in Austria has remained the same over the last 18-24 months and GSME
Recommendations have not necessarily led to a reduction of complaints. Concerns have
also been raised about reductions in property value (with ongoing lawsuits).
Codes of All Austrian operators report: 1) that voluntary agreements with the Association of
practice & Austrian Communities have been in place since 2001. These cover the provision by
Audit operators of technical information to the local community (Mayors) prior to site
process installation. The community has a say in the way that information is provided. 2)
Mobile Phone Charters are in effect in three Austrian provinces. These Charters cover
the provision of planning information and the participation of communities in the
planning process.
Voluntary The following information is also provided for each new base station: a basic brochure
actions from on health and technology issues; a standard technical information sheet. The “Dialogue
MNOs Handbook Mobile Communication” brochure is provided regularly to communities. In
some cases, operators provide information annually to communities, which are affected
by planned sites and offer to discussions. This offer is rarely taken up, especially in
communities with known health fears.
Government The government provides precautionary advice regarding the use of mobile phones (e.g.
/Other to reduce call time and advice for mobile use by children).
actions
Exposure EU Recommendation (legislation) – Ref: ÖVE/ÖNORM 8850 (01/02/2006). The exposure

guidelines limits are harmonized with the values proposed by ICNIRP. An Austrian technical
standard ÖNORM is not legally binding, but defines the state of the art and experts use
them in administrative proceedings and they can be imposed by official notifications.
.
48
I.2 Belgium
Rec.#1 & 9 Operators report that there is a national policy covering good practice for network
rollout and one operator makes reference to the GSME Recommendations for network
deployment. There are national mandatory requirements: to communicate the need to
install more network antennas to the public; to provide detailed technical and
supporting deployment justifications with each application to the local authority or other
regulatory body; to have a monitoring and documentation system for information
exchange process in place; to audit and publish results of the monitoring of the
information exchange process. The main stakeholders are local authorities, the
regulator, the public and local communities, to whom information flow is facilitated by a
regulated consultation processes. A nation-wide format is used by every operator and
the information includes: details of the planned site; potential impact to the
environment; health and technology information, and photo montages. The information
is publicly available on regulator’s site 63 .
Rec. #2 Operators share sites with other operators’ facilities, tower and roof-mounted sites,
other telecommunications masts and antennas, and utilities’ facilities. In Belgium,
operators have established RISS (Radio Infrastructure Site Sharing) association, which
is managed in conjunction with the Regulator. This helps optimise the sharing of sites
and manage problems arising with different authorities. The main reasons for site
sharing are the requirements imposed by local authorities and environmental and
landscape preservation. There is a formal administration process for site sharing and
site sharing is expected to remain at least at the same level over the next five years or
probably increase.
Rec. #3 Alternative designs to reduce visual impact are used by operators and relevant
guidelines are in place. Building permit regulations require a review of the visual impact
of every installation. Building permit procedure exemptions vary by region, with some
exemptions for micro-sites and additions to existing sites.
Rec. #4 Respondent(s) provide information on existing and new services and technologies, in
which services, benefits, possible impact, infrastructure requirements, timescales of
development and public consultation information are detailed. The regulator and
regional authorities are closely involved in the process and are aware of the
evolutionary processes in the mobile industry. Educational sessions are held on a case-
by-case basis in response to specific requests from a municipality. Despite these
sessions, feedback shows that the public concern remains high.
Rec. #5 Operators report that base stations comply with national and European exposure limits.
Rec. #6 Operators report that 100% of sites are certified. They have policies for their own
employees when accessing areas close to antennas and provide guidelines for third
parties e.g. painters or construction workers working in or around antennas. One
operator reported that pre-installation calculations and measurements, and regular
63
http://www.ibpt.be/Home.aspx?levelID=1&lang=en
.
49
post-installation measurements are carried out when commissioning a new site, to

ensure compliance with the regulator’s limits. RF measurement monitoring is performed
by the regulator and by the operator on a case-by-case basis.
Rec. #7 Operators have processes in place to address issues raised at the national level, those
raised through the national trade association (GSM Operator’s Forum, GOF) and
individual issues. The processes are managed by specialist staff, being responsible for
the communication with local residents. There are telephone hotlines, named contact
personnel who liaise with local authorities and websites that receive enquiries and
dispatch information. The GOF coordinates the exchange of information. The response
times to public complaints and enquiries are monitored.
Rec. #8 Operators support national government studies, individual company research and
corporate (group-wide) research and participate in university think tanks. The results of
the studies are published and often used to help inform municipalities and the general
public about that a particular request for building permission is free of health issues.

Level of It is reported that the level of concern in Belgium has increased over the last 18-24
concern months with health and environmental issues at a high level, and aesthetics being a
medium level concern.
Operators report that there are delays in obtaining building permissions due to
increasing health concerns from the public. Belgian operators have three kinds of
building permit legislation in Belgium, each in a different language.
Codes of A combination of mandatory requirements and national policies apply.

practice &
Audit
process
Voluntary One operator highlighted that when dealing with local authorities there are compromises
actions from needed. Good coverage is a requirement, but if there are requests for tougher limits by
MNOs local authorities for the antenna electric field strength levels (3V/m) then this will result
in more sites, which creates additional visual and environmental impact – issues which
the public dislike, whilst still complaining when they have poor service quality.
Government The government takes precautionary actions beyond power limit guidelines and provides
/Other precautionary advice for the use of mobile phones (e.g. reducing call time, advice for
actions mobile usage by children)
Exposure EU Recommendation (legislation, stricter limits for mobile frequencies) – Ref: Royal
guidelines Decree 10/08/2005
I.3 Bulgaria
.
50
Rec.#1 & 9 Respondent(s) have a policy for good practice for network rollout. Information is
provided on a voluntary basis to the local authority and the public on current and future
network deployment plans as well as on the need to install new base stations. There is a
mandatory requirement to provide detailed technical and supporting deployment
justifications with each site application to the local authority or other regulatory body for
all operators. Other information provided includes: an assessment of the environmental
impact; potential impact/ benefit to the community; health related info and a
description of the proposed site including computer generated images or photo
montages. A company standard format is used in some cases. Information flow to
stakeholders is facilitated through educational sessions and road shows, letters to
nearby residents and one to one sessions, mainly when there is a new deployment, but
also on request from the public.
Rec. #2 Various site sharing methods are used: with other operators’ facilities, tower sites,
transmission equipment shelters, other telecommunication masts and radio
installations. 100% of 3G sites are shared with 2G sites. It is believed that site sharing
will increase over the next five years.
Rec. #3 Alternative designs to minimise visual impact of network deployments are used.
Rec. #4 Respondent(s) provide information on existing and new services and technologies, in
which services, benefits, possible impact and data for public consultation are detailed.
The use of lower frequency bands to reduce the number of sites required for 3G services
is at an early stage of consideration.
Rec. #5 Respondent(s) reported base station compliance with national and ICNIRP exposure
limits.
Rec. #6 100% of sites are reported certified. Policies for company employees accessing areas
close to antennas are in place. One operator performs pre-installation calculations,
monitors and measures the RF exposure in public areas from sites when they become
operational (regulatory requirement).
Rec. #7 Respondent(s) report having processes in place, with specified response times, to
address individual issues (e.g. consumer or site-specific), mainly through named contact
personnel for liaison with local authorities.
Rec. #8 GSMA programmes and initiatives are supported by the operator.

Level of It is reported that the level of concern in Bulgaria has increased over the last 18-24
concern months with health issues at a higher level, and environmental/ aesthetic issues being
of increasing concern.
It is reported that base station permission procedures have become stricter as more
public agencies are getting involved into the permission process.
.
51
Codes of One operator is in the early phases of developing and implementing a corporate (group-
practice & wide) EMF policy.
Audit
process
Voluntary Information flow is facilitated through educational sessions and road shows, letters to
actions from nearby residents and one to one sessions, mainly when there is a new deployment or
MNOs upon request by the public.
Government The government has implemented precautionary actions beyond limit guidelines (e.g.
/Other exclusion zones for masts, in-site measurement programmes) together with the
actions provision of precautionary advice for the use of mobile phones (e.g. reducing call time,
advice for mobile usage by children).
Exposure There are national guidelines which are not based on ICNIRP:
guidelines
a. General public: Reference Levels: 0.1W/m2 (0.3 – 30 GHz) – Ref: No.9
(14/03/1991), MPEs for Electromagnetic Radiation in Residential Areas and for
Determining Safety Zones Around Electromagnetic Sources, Governmental News
No.35/1991.; No.7, Gov. News No.46/1992 - Hygienic Requirements for Health
Protection of the Residential Areas.; BNS 14525-90, Radiofrequency Electromagnetic
Fields. Permissible Levels and Control Requirements.
b. Occupational: Reference Levels: 10W/m2 (300 MHz – 300 GHz) – Ref: No.7, Gov.
News No.88/1999 for the Minimal Requirements for Healthy and Safety Work Conditions
I.4 Cyprus
Rec.#1 & 9 Respondent(s) have adopted a company policy for good practice for network rollout,
making reference to GSM Europe Recommendations. A formal process to communicate
and provide information to the local authority/ the public on current and future network
deployment plans is a mandatory requirement, while the need to install more base
stations is communicated voluntarily on a case by case basis. A consultation programme
is also conducted on a voluntary basis, where local communities are involved in the
categorisation of proposed sites. A monitoring and documentation system for
information exchange process has been implemented. The local authority and the
community are the main stakeholders of the information exchange process, which is
facilitated through information session/ road shows, seminars, public/ media
announcements and one to one sessions. Information is provided on the planning
framework, the potential impact on the environment and the community, technology
and health information together with photo montages of the proposed sites. The
information is provided when there is a new development or upon request from the
public.
Rec. #2 Respondent(s) share sites with other operators’ and broadcasting companies’ facilities,
.
52
tower and roof-mounted sites, transmission equipment shelters and other

telecommunication masts. All 3G sites are shared with 2G sites. A formal process is in
place for administrating site sharing. Site sharing is expected will increase over the next
five years.
Rec. #3 The operator reports making use of alternative designs.
Rec. #4 It is reported that information on possible infrastructure requirements is provided, while

technical operating information on the construction of each site is also provided
voluntarily to the local authority. Detailed technical and supporting deployment
justifications with each application to gain authorisation from local authority or other
regulatory body are also made available.
Rec. #5 Respondent(s) report base station compliance with national exposure guidelines.
Rec. #6 All sites are reported to be certified. The operator has processes in place for its own
employees when accessing areas close to antennas. Third parties e.g. painters or
construction workers are also given guidelines when working in or around antennas.
EMF measurements are carried out for all the base stations twice a year. This is not only
due to a requirement from the regulator applying to all operators, but also to address
public concerns. Regular measurements are also part of the company’s communication
policy.
Rec. #7 There are processes in place to address individual issues (e.g. consumer or site-specific
enquiries). Complaints/ enquiries are handled by specialist staff, communicating and
managing these processes with local residents.
Rec. #8 Survey participant(s) report that support GSMA / GSM Europe programmes and
initiatives. The EU and WHO research and guidelines are monitored. The operator makes
research results available to public, promotes awareness of results and informs
authorities/public of the WHO and EU research agendas.

Level of It is reported that the level of public concern has increased over the last 18-24 months.
concern Health related concerns are in high level and environmental/ aesthetic concerns are in
medium levels.
Codes of An operator uses GSM Europe Recommendations as a reference.

practice &
Audit
process
Voluntary There is an ongoing process of preparing an explanatory book on EMF issues, and plans
actions from to increase interaction and meetings with local mayors in the near future.
MNOs
.
53
Government Since 2004, base station compliance is included in the National Radiocommunications
/Other (Authorizations) Regulations. 64
actions
Exposure EU Recommendation – Ref: National Radio-communications (Authorizations)

guidelines Regulations of 2004
I.5 Czech Republic

Rec.#1 & 9 Operators report that they have formal company policies for good practice for network
rollout. A formal process to communicate and provide information to the local authority/
the public on current and future network deployment plans together with the need to
install more network antennas to the public is followed on a case by case basis. Detailed
technical and supporting deployment justifications with each application and technical
operating information on the construction of each site to gain authorisation from local
authority or other regulatory body is a mandatory requirement. Other information
provided includes planning framework, potential impact to the environment and benefit
to the community, technology and health information. Description of the proposed site
including computer generated images or photo montages are also made available. A
monitoring and documentation system for information exchange process is also required
by operators. No auditing of this process is performed. The public or local community is
also involved in the process. The information is provided when there is a new
development or when it is requested by public/ community, and is provided by
consultation processes, information sessions/ road shows and one to one sessions. The
format of the information varies depending on the project and the persons involved. The
general feedback is that information provided is considered as explanatory,
understandable and sufficient for the purpose.
Rec. #2 All operators report site sharing with existing infrastructure (tower and roof-mounted
sites, transmissions equipment shelters, antennas and other telecommunications masts.
3G sites are shared in almost 100% with 2G sites. Site sharing in the Czech Republic is
comparable low, but it is believed that will increase over the next five years. The main
reason for site sharing is cost saving, but environmental and landscape preservation are
also considered important by operators.
Rec. #3 All operators report the use of alternative design to reduce visual intrusion. Examples
include artificial pine trees, artificial chimneys, special designs at gas stations and
special designs on historic buildings.
Rec. #4 All operators provide information on new services/technologies: a description of

services, benefits and possible impact. In some cases educational sessions are held to
explain to the local authority how the technology works or why the sites have to be
established in the specified locations. It is reported that, regarding EMF impact,
64
http://www.gsmworld.com/gsmeurope/events/hes_seminar2/mobile_comms_matters.pdf
.
54
operators are successful in providing explanations in more than 80% of cases.

Generally, information provided is considered as sufficiently explanatory and
understandable. The deployment of 3G networks in lower frequencies (potentially
resulting in fewer sites) is in early discussions with the regulator.
Rec. #5 All operators report base station compliance with European exposure guidelines.
Rec. #6 All operators report 100% certified sites. Processes are in place by all operators to
ensure compliance with the EU Directive recommendation for occupational exposures
together with policies for their own workers when accessing areas close to antennas
(e.g. on each site there is list of operational rules which specifies safe distances for
workers at which the limits are not exceeded). Operators also provide guidelines for
third parties e.g. painters or construction workers working in or around antennas. Pre-
installation calculations are always submitted and Post-installation measurements are
performed on a case by case basis.
Rec. #7 All operators have processes in place to address individual issues (e.g. consumer or
site-specific). Operators have established EMF teams which response immediately or
within 24h by personal contact or by written explanation when requested. Other means
of response include telephone hotlines and web-sites that receive enquiries and dispatch
information and a special interactive presentation which contains more than 30 topics
(created on the basis of frequently asked questions).
Rec. #8 Operators support corporate (group-wide) research studies. One of the operators also
supports GSMA initiatives and programmes. It is reported that results from this research
are very helpful to argument discussions with the public. If there is negative public
reaction to Internet articles (usually sensational) then operators make use of arguments
based on scientific studies.

Level of The level of concern in Czech Republic has been generally stable over the last 18-24
concern months. Health and Environmental concerns are at a low level. Aesthetic concerns are in
medium level. The implementation of GSME Recommendations has not necessarily
reduced the level of complaints.
Operators report that recently there are public claims that the price of real estate will
much lower if there is a base station on or near it. There are also cases where landlords
are requesting increasing rent for lease contracts.
Codes of Operators provide the regulatory and planning authorities information requested by law.
practice & It includes information necessary for obtaining building permission (e.g. technical
Audit documentation, hygienic calculation, and statements of all respective authorities). If
process information beyond the legal requirement is required, operators provide this also. Some
operators use a brochure to provide general information (explaining GSM principles,
network building methods and other related issues). Operators use a special interactive
presentation which contains more than 30 topics (created on the basis of frequently
asked questions) and other supporting material.
Voluntary Operators have adopted a corporate (group-wide) approach to EMF policy. These
.
55
actions from policies are a voluntary commitment to transparency, information provision,

MNOs consultation and participation. All operators provide an “Overall Conception of All Base
Stations in Protected Areas” which covers a 5 year planning period and includes base
stations already built by all operators. Protected Areas represent about 13% of the
Czech Republic area. There are regular meetings with authorities from Protected Areas
where the base stations in question are reviewed and an acceptable means of
deployment are considered whilst ensuring minimal impact on the environment.
Government Information related to actions regarding EMF activities can be found at WHO’s web
/Other site. 65
actions
Exposure EU Recommendation (legislation) – Ref: Governmental Decree No 480/2000, Public and

guidelines Occupational
I.6 Denmark

Government Information related to actions regarding EMF activities can be found at WHO’s web
/Other site. 66
actions
Exposure EU Recommendation (no known plans for legislation) - Ref: Labour Inspectorate follows
guidelines the ICNIRP recommendations when evaluating exposure, Public and Occupational
I.7 Estonia

Exposure EU Recommendation (legislation), Public Regulation of the Government of Estonia on
guidelines occupational health and safety limits – Ref: 86/188/EEC (22/01/2002), Occupational
I.8 Finland
65
http://www.who.int/peh-emf/project/mapnatreps/czechrepublic/en/index.html
66
http://www.who.int/peh-emf/project/mapnatreps/denmark/en/index.html
.
56
Rec.#1 & 9 In Finland, operators have company policies for good practice for network rollout,
following the procedures given by the Finnish Telecommunication Authority. Operators
communicate and provide information to the local authority/ the public on current and
future network deployment plans on a case by case basis. They also communicate the
need to install more network antennas to the public. Detailed technical and supporting
deployment justifications with each application to gain authorisation is provided to the
local authority or other regulatory body. Consultation programmes or involvement of
local communities in the categorisation of proposed sites take place. Information flow is
also facilitated by information sessions/ road shows, public/ media announcements and
one to one sessions. Other information includes planning framework, potential impact
on environment / benefit to community, technology and health information.
Computerised images or photo montages are also produced. The information format
varies depending on the project and the person involved and is provided when
requested by the public.
Rec. #2 Respondent(s) reported site sharing with other operators’ facilities, tower and roof-
mounted sites, other telecommunications masts, radio installations and utilities’
facilities. Formal administration processes are followed for site sharing. All 3G sites are
shared with 2G sites. Cost saving, environmental concerns and landscape preservation
are the main reasons. It is reported that site sharing will increase over the next five
years.
Rec. #3 It is reported that alternative designs are implemented to reduce visual impact of sites
(e.g. painted antennas to match background colour, installation inside church towers),
following specific guidelines.
Rec. #4 Respondent(s) provide information on existing and new services/technologies:

description of services, benefits, possible impact, possible infrastructure requirements
and public consultation information. Educational sessions to explain to the local
authority how the technology works or why the sites have to be established in the
specified locations are held on a case by case basis. Feedback is usually good. An
operator is considering the use of lower frequency bands to reduce the number of 3G
sites required.
Rec. #5 Respondent(s) report base station compliance with European exposure guideline.
Rec. #6 All operators’ sites are certified. There are processes to ensure compliance with the EU
Directive recommendation for occupational exposures; policies for company employees
accessing areas close to antennas (e.g. safety distances, power-switch off, written
material) and specific guidance is given to third party workers on a case by case basis.
RF measurements are performed in response to the concerns of the public, or others
(including spot measurements).
Rec. #7 Respondent(s) have processes in place to address issues raised to the company at a
national level, to address issues through a national Trade Association and to address
individual issues (e.g. consumer or site-specific). Processes are handled by specialist
staff for managing and communicating issues with local residents, there are telephone
hotlines and web-sites that receive enquiries and dispatch information, and the
established Trade Association representing network operators coordinates information
.
57
exchange. The processes and the response times are monitored.
Rec. #8 National government research and GSMA programmes and initiatives are supported by
operators. Respondent(s) promote the awareness of the results and make use of them
in contacts with stakeholders, the public and authorities.

Level of The level of concern has increased over the last 18-24 months, although one operator
concern reports that GSME Recommendations have reduced the number of complaints/ enquiries
over the last two years. Health and environmental concerns are at a low level, but with
an increasing trend. Aesthetic and technology concerns are at a medium/ low level.
Codes of Operators report that the public is mainly concerned about the effects of base stations
practice & to children, subjective symptoms and cancer fears. Public concerns are slowly increasing
Audit in some areas, decreasing in some others.
process
Voluntary The National EMF Research Program HERMO includes research into children’s issues,
actions from body implants, cognitive issues, blood circulation, ear-balance function etc.
MNOs
Government Project HERMO is budgeted at €1.5 million, with 60% funding from the Finnish
/Other government. 67
actions
Exposure EU Recommendation (legislation) – Ref: Decree on the limitation of exposure of the

guidelines public to non-ionizing radiation 294/2002, based on the Law on radiation protection
592/1991, 43
I.9 France
Rec.#1 & 9 All operators report a national policy for network rollout good practice. Operators always
follow a formal process to communicate and provide information to the local authority/
the public on current and future network deployment plans. The need to install more
network antennas is communicated to the public on a case by case basis. Information
on health and technology issues is also provided. A description of the proposed site
including computer generated images or photo montages is also made available. This
information is provided when there is a new deployment or when requested by the
public. Operators conduct consultation programmes or involve local communities in the
categorisation of proposed sites and provide technical operating information on the
construction of each site to the local authority. Operators also have in place a non-
audited monitoring and documentation system for information exchange. Information
flow is mainly facilitated by sessions and road shows. A nation-wide information format
67
http://www.gsmworld.com/health/programs/finland.shtml
.
58
is used by every operator in the country.
Rec. #2 Operators report site sharing with other operators’ facilities, tower and roof-mounted
sites and other telecommunications masts. Cost saving, environmental and landscape
preservation are the main reasons. It is reported that site sharing will increase over the
next five years.
Rec. #3 Operators report the use of alternative designs to minimise visual impact, following the
French Mobile Phone Operators environmental guidelines: “Antenna deployment
environmental harmonisation guide”.
Rec. #4 Operators provide information on existing and new services/technologies: description of

services, benefits, possible impact, possible infrastructure requirements and public
consultation information. When it is requested by the local authority, education sessions
are held to explain how the technology works or why the sites have to be established in
the specified locations. The sessions are generally appreciated with local authorities able
to respond to public enquiries about radio-communication infrastructure.
Rec. #5 Operators report base station compliance with European exposure limits.
Rec. #6 Operators have implemented policies for company employees accessing areas close to
antennas (e.g. internal safety guidelines, compliance boundaries, charts and
pictograms). Safety information is also provided to the landlord. Operators perform pre-
installation calculations, and after the commissioning of a site, exposure measurements
are performed when required by local town or county charter. Site measurements are
performed as required by the operator’s communication policy and as a commitment to
residents who live or work near the base station.
Rec. #7 Operators have processes in place to address issues raised to the company at a national
level, which are addressed through the national Trade Association (Association française
des opérateurs mobiles, AFOM) and to address individual issues (e.g. consumer or site-
specific). The Guide for Good Practice between Mayors and Operators states that
operators should organise public meetings to answer any concerns about health and
environmental issues. Operators are required to answer enquiries from the public or
organisations within one month and they employ specialist staff to manage
communications with local residents. Complaints and enquiries are also handled by
AFOM representing network operators and the association coordinates the exchange of
information.
Rec. #8 Operators support national government research studies: in January 2005, a

governmental decree established a public utility body called the 'health and radio
frequencies Foundation' (Fondation santé et radiofréquences). The Foundation was set
up to carry out independent research into radiofrequencies and health effects, with
financial participation of operators and manufacturers. Projects selected by this
Foundation are aligned with the WHO research agenda.

Level of It is reported that the level of concern has remained the same over the last 18-24
concern months. Health and environmental concerns are at a high level. Aesthetic concerns are
.
59
at a medium level.
Operators report that the mixture of existing 2G signals with new signals from 3G or
other wireless equipment (e.g. Wi-Fi) is a growing concern.
Codes of Operators in France follow a good practice guide (Guide des Bonnes Pratiques, GBP) 68 ,
practice & which includes environmental guidelines and has been agreed between the Mayors and
Audit operators. The documents (published in 2004) are available on the French mobile
process operators’ association website. A survey of 400 Mayors carried out after one year’s use
of the Guide of Best Practice, is available on AFOM’s website 69 . The deployment of base
stations follows emission permits delivered by ANFR (National Frequencies Agency) and
urban planning code. Operators provide Key Performance Indicators (KPIs) to AFOM,
with regard to network rollout.
Voluntary The French Health and Radiofrequencies Foundation was created to encourage research
actions from efforts to study the effects of RF electromagnetic waves on humans, as well as provide
MNOs information on this subject to the public, governments, doctors, professionals and
others. Its budget is €1.8 million (half of the Foundation's budget is State-funded, and
half is provided by industry). 70
Government Government provides precautionary advice for the use of mobile phones (e.g. reducing
/Other call time, advice for mobile usage by children).
actions
Exposure EU Recommendation (no known plans for legislation) – Ref: Decree No.2003-961
guidelines (08/10/2003), regarding the conformity assessment of mobile terminals + Decree N°
2002-775 (05/03/2002) regarding base stations and fixed radio terminals; UTE C 99-
111 - Recommendation concerning exposure of workers to electromagnetic fields),
Occupational.
I.10 Germany
Rec.#1 & 9 All mobile operators obligated to communicate and provide information to local
authorities on current and future network deployment plans, including detailed technical
and planning frameworks and the potential impact to the environment, and health
information. In some cases computer generated images are also available. Operators
are also required to provide information for new antenna installations, and consultation
programmes are conducted with local communities. Information may be provided
annually; when there is a need for new development or when it is requested by a public
or local authority. Other communications include information sessions/ road shows,
seminars, public/ media announcements and one to one sessions, if required. The
Agreement between the Central Municipal Organizations and the operators provides a
68
http://www.amf.asso.fr/documents/document.asp?ID_DOC=7311&REF_SPA=01&ref_arbo=139
69
http://www.afom.fr/v4/FILE_DOWNLOAD.php?doc_ID=693&mode=directOpen
70
http://www.gsmworld.com/health/programs/france.shtml
.
60
basis for communications and there is a data base operated by the Federal Network
Agency. The information exchange process is usually based on a standard company
format or national-wide procedure, it is audited and the results are published 71 .
Rec. #2 All four operators share sites with existing infrastructure (tower/ roof mounted site,
other operator’s site, other telecommunications mast or radio installation). Site sharing
is required by local authorities. Other reasons for site sharing are landscape
preservation, environmental concerns and cost saving.
Rec. #3 Operators in Germany make use of alternative designs on a case-by-case basis to

reduce the visual impact of the sites, and there are planning exemptions on most
antennas (a formal planning permission is required for antennas above 10m).
Rec. #4 Mobile operators inform the planning and regulatory authorities about technological
developments in mobile telecommunications (existing and new services, benefits, and
possible impact; infrastructure and timescale requirements) and undertake public
consultation. Educational sessions are held with local authorities to provide site
justification in parallel with network rollout or during planning/ coordinating meetings.
Responses from the authorities are perceived as positive.
Rec. #5 All operators report base station compliance with national and EU exposure guidelines.
Rec. #6 All sites across all operators are certified and formal processes are in place to ensure
compliance with the EU Directive for occupational exposure. Site measurements are
performed as part of each company’s communication policy or in response to concerns
from the public or others. All operators have policies for their own employees when
accessing areas close to antennas. Guidelines are provided to third parties working in or
around the antennas.
Rec. #7 All operators have processes in place in order to address issues raised: to an operator at
the national level; through the national mobile information centre IZMF and as
individual cases (consumer or site-specific). Specialist staff is assigned to manage
communications with local residents. There are named contact personnel (e.g. a local
authority contact partner) for liaison with local authorities and enquiries can be
submitted via web-sites or on telephone hotlines. Brochures, web information and
71
Extract from the Common press releases of the Federal Environment Ministry and the Federal Ministry of
Economics 31.03.2005 – English translation: “According to the auditors, communication and participation
between Mobile Operating Companies (MOCs) and municipalities on the basis of the self-commitment is in
principle working well.”
Extract from Annual report concerning compliance with the voluntary commitment on the part of the mobile
telecommunications network operators - 2004 (page 4, 2nd paragraph): “The most important result is that
the overall situation regarding information, cooperation and participation compared to 2002 has clearly
relaxed and improved. Overall, communication and participation on the basis of the voluntary commitment
and the inter-association agreement function well. However, in isolated cases as well as regarding details
problems continue to exist.”
Extract from Common press releases of the Federal Environment Ministry and the Federal Ministry of
Economics 18.03.2003 – English translation: “Significant improvement of the co-operation between mobile
network operators and municipalities.”
.
61
proactive information campaigns are conducted for local authorities, schools, medical
professionals and parents. IZMF, representing network operators, coordinates the
exchange of information. In some cases established processes are in place to monitor
response times to enquiries. It is reported that actions taken by operators have in
general reduced the number of EMF complaints/ enquiries.
Rec. #8 All operators support national research studies. GSMA programmes and initiatives are
also supported. Dissemination of results to relevant stakeholders and the public is an
integral part of the research programme. The Research Association for Radio
Applications publishes a quarterly newsletter and a weekly e-mail newsletter. Each
operator made a proportionate contribution to the research with a total sum of €8.5
million allocated for the period from 2002 to 2005. They are prepared to further support
research as recommended by the relevant expert panels

Level of Over the last 18-24 months the level of concern related to network rollout has remained
concern the same. In Germany, health and aesthetic concerns are at a medium level, and
environmental concerns are at a medium/ low level. Operators’ activities related to
GSME Recommendations have led to an overall reduction in the level of complaints and
enquiries.
The most frequent concerns are related to general health and the established processes
for dialogue with local authorities have helped to reduce concerns. The situation has
improved since voluntary communications measures were implemented.
Codes of The basics of the information exchange between operators and communities are laid
practice & down in two documents:
Audit
- “Agreement on Exchanging Information and Involving Local Communities with
process
Regard to expanding Mobile Radio Networks between the “Central Municipal
Organizations” and the “Mobile Radio Network Operators”
- “Measures for improving safety and consumer, environmental and health

protection, information and confidence-building measures in setting up Mobile Radio
Networks”
All elements of the GSME Recommendations are included in the network rollout good
practice in Germany although not specifically referenced. The second document also
provides consumer information on Specific Absorption Rate (SAR), research funding and
independent field monitoring. These documents demonstrate industry commitments to
meet mandatory requirements which are supported with annual reports to the
government. The mobile radio operators report to the German government at least
annually.
Voluntary Each of the mobile radio network operators provides a proportion of the funds to
actions from support the registration scheme for high-frequency electro-magnetic emissions within
MNOs the government’s Existing Measurement Programme.
Prior to 2 January 2005 when they were merged, there were separate databases to
track municipal locations and also a separate public EMF database. In the future there is
.
62
an intention to include test measurements from federal states those of the Federal
Network Agency.
In co-operation with the ministries for the environment of federal states, the Federal
Network Agency has drawn up an implementation plan for the realisation of the
Monitoring Programme with 12 monitors, which started on 19 March 2007. Currently 10
monitoring systems are in operation. All measurement results are available on the
Agency's web site. The monitoring systems send their data via GPRS to the Agency. The
results of the measurements are updated on the web page once per hour.
Government Precautionary measures of the Federal Government in the area of mobile

/Other communication 72 :
actions
- Provision of precautionary advice for the use of mobile phones (e.g. reducing call
time, advice for mobile usage by children)
- Retention of the current threshold limits
- Intensification of scientific research
- Creation of a database of the authorized locations of mobile communication

antennas
- Information to the public on the current state of scientific knowledge
- Self-commitment and monitoring
Exposure EU Recommendation – Ref: 26th BImSchV (16/12/1996), Ordinance for implementing

guidelines the Federal Emission Control Act; Ordinance on Electromagnetic Fields, Public and
Occupational
I.11 Greece
Rec.#1 & 9 Operators have formal company policies for good practice for network rollout, which
refer to the GSME Recommendations, and operators communicate the need to install
more network antennas to the public. It is a mandatory requirement for operators to
provide detailed technical and supporting deployment justifications with each application
to the local authorities or other regulatory body. Operators in Greece are obligated to
provide: a technical evaluation study for each new or upgraded base station (including
technical calculations, plans of the construction, etc); environment impact studies for
each new or upgraded base station (including technical calculations, plans of the
construction and of the surrounding areas to a radius of 300m, updated information on
health issues, WHO statements, etc.). These studies are based on the requirements of
the regulatory framework (national licensing process).
Information on the potential impact on the environment/ community and health

information are also made available. In some cases consultation programmes are
72
Source: Federal Chancellery (2001)
.
63
conducted and local communities involved in the categorisation of proposed sites.

Operators have monitoring and documentation systems processes in place. Information
is provided either: annually; when there is a new deployment or when it is requested by
a public or local authority.
transmission equipment shelters, antennas, other telecommunications masts and radio
installations and utility facilities. 100% of 3G sites share facilities with 2G sites. Cost
saving and in some cases landscape preservation are the main reasons for site sharing.
Site sharing is expected to increase over the next five years.
Rec. #3 Operators use alternative designs to reduce a site’s visual impact.

services, benefits and possible impact. In some cases, operators provide details of the
possible infrastructure requirements, the timescales of the development and other
public consultation information. Operators conduct educational sessions as needed, to
explain to the local authority about technology developments and the reasons for sites
being required in specific locations. The responses to these sessions depend on the
audience but are positive or neutral. It is rare for presentations and meetings to have a
negative impact, although in some cases there is no public interest. Many discussions
have taken place with the regulators regarding the 900 MHz spectrum re-farming for
3G, which may reduce the number of sites required because of the technical
characteristics of operations in the 900 MHz band - decisions will be in line with EU
recommendations. Operators meet electromagnetic exposure compliance requirements.
Rec. #5 Operators report base station compliance with National exposure limits. These are
stricter then ICNIRP. Even though ICNIRP guidelines are adopted there are additional
safety factors, e.g. for the general public the Greek limits are set at 70% of the
EU/ICNIRP limits. For areas within 300m of “sensitive buildings” such as schools and
hospitals, the base station network should comply with a limit which is 60% of the
EU/ICNIRP guideline.
Rec. #6 All sites are reported as certified. There are policies for company employees when
accessing areas close to antennas and guidelines for third parties e.g. painters or
construction workers working in or around antennas via the subcontractor. One operator
reports monitoring/measuring the RF exposure in public areas. This may be done ad-
hoc, upon request and sometimes voluntarily for a sample of base stations. Site
measurements are part of the company's communications policy and are performed in
response to public concern. The operator’s policy for occupational exposure safety
addresses the requirements of the EU recommendation.
Rec. #7 Operators have processes to address issues raised to the company at the national level
and also to address individual issues (e.g. consumer or site-specific). These processes
are handled by specialist staff to contact local residents and named contact personnel
for liaison with local authorities. There are also telephone hotlines and web-sites that
receive enquiries and dispatch information. Response times are in some case monitored.
Rec. #8 Operators support GSMA programmes and initiatives. Research progress and results are
.
64
provided to authorities/public together with any further detailed information requested.
Level of The level of concern remains high lover the past 18-24 months and operators report
concern that GSME Recommendations have not necessarily reduced the level of complaints or
enquiries. Health related concerns are reported as increasing over the last two years
and being at a high level. Environmental, aesthetic and technology concerns are at a
medium level.
Operators report difficulties in implementing sites due to public protests, which

sometimes require police intervention.
Codes of As part of its corporate (group-wide) policy, one operator has adopted the “Responsible
practice & Network Deployment Guidelines Policy”, which addresses all elements of the GSM
Audit Europe Good Practice Recommendation on Network Rollout.
process
Voluntary One operator reports that it has implemented the “EMF transparency” programme;
actions from Information about EMF measurements is provided to the public by independent
MNOs authorities (e.g. universities).
Government The Greek government implements precautionary actions (e.g. exclusion zones for
/Other masts, in-site measurement programmes) which are beyond those included in
actions guidelines. The Greek Regulatory Authority has organised several workshops on mobile
technology and EMF issues to inform the public.
Exposure EU Recommendation (legislation) with additional safety parameters – Ref: Law No

guidelines 3431,Act No.13/A/3-2-2006 “About electronic communications and other provisions”
I.12 Hungary
Rec.#1 & 9 All operators have a formal company policy for good practice for network rollout.
Voluntary processes have been established to communicate information to the local
authorities and the public on current and future network deployment plans. The need to
install more network antennas is communicated to the public on a case by case basis.
When site permission is required by the National Construction Constitution or by local
decrees, operators provide detailed technical and supporting deployment justifications
with each application to the local authority or other regulatory body. The information is
also provided to the public or local community and the National Public Health and
Medical Officer Service (ÁNTSZ) is also informed. Consultation programmes provided as
needed, on a case-by-case basis. Operators also provide information through
information sessions/ road shows, public/ media announcements, letters to nearby
residents, the national EMF portal and with an informative leaflet which covers issues
such as: network building; technical and legal background; responsible authorities;
.
65
potential impact to environment/ community; 3G technology; FAQ about sites;

emissions and power; the WHO position; photo montages and information forums. A
format used depends on the project and personnel involved. No auditing process in is
place for monitoring the information exchange process and although in general the
perception is good, feedback is not always provided.
Rec. #2 Operators report site sharing with existing infrastructure (other operators’ facilities,
tower and roof-mounted sites, antennas and other telecommunications masts and
utilities’ facilities e.g. water-towers, churches, silos). A formal administration process for
site sharing has been implemented and on average, more than 50% of sites are shared.
This percentage is expected to increase over the next five years. Co-location with other
operators’ infrastructure is around 40% and 95% of 3G sites are shared with 2G sites.
Cost saving and environmental concerns are the most important reasons for site
sharing.
Rec. #3 Alternative designs are implemented in Hungary, although there are no specific
guidelines. Examples include artificial trees, advertising signs and hidden antennas.
Rec. #4 Operators provide information on existing services/technologies: description of services,

benefits and the possible impact. The operators have to purchase a software platform
which enables them to submit detailed data (e.g. antenna data, cell data,
frequency/power/bandwidth data and post-installation changes) to the regulator.
Educational sessions are conducted to explain to the local authority how the technology
works or why the sites have to be established in the specified locations. The feedback
from participants to these sessions is variable. Some industry players are already
considering the deployment of 3G in lower frequencies, although in this case, a
regulatory decision will be required.
Rec. #5 Respondent(s) reported base station compliance with national and European exposure
guidelines.
Rec. #6 The regulator requires sites to be measured. Pre-installation calculations and post-
installation measurements are performed. Operators report monitoring and measuring
the RF exposure in public areas from their sites when first commissioned and, in some
cases, at regular intervals subsequently. An independent body is responsible for site
sample selection. Measurements are performed to meet regulatory requirements and in
response to public or other concerns. On average, more than 60% of sites are certified.
Operators have processes to ensure compliance with the EU Directive recommendation
for occupational exposures and policies for company employees accessing areas close to
antennas.
Rec. #7 Operators have employed specialist staff to manage communications with local
residents. Telephone hotlines and web-sites have also been established to receive
enquiries and dispatch information. Operators have processes to handle complaints at
individual level (e.g. customer or site specific) and response times are sometimes
monitored.
Rec. #8 The operators support corporate (group-wide) and national research studies. Results of
the research studies are made available to the public via operator’s web sites, the
Hungarian EMF-portal and books.
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Level of The level of concern in Hungary has remained at the same level over the last 18-24
concern months. GSME Recommendations have possibly led to fewer complaints. Health issues
are at a medium level, while environmental, aesthetic and technology issues are at a
low level.
Codes of Operators report that EMF concerns may lead to property devaluation and, due to
practice & political interest and increasing reactions from green activist, local regulation gets
Audit stricter. It is also reported that site deployment in most districts of Budapest is
process practically impossible because of local decrees.
Voluntary One operator reports auditing building sites including site signage.
actions from
MNOs
Government In some cases operators mark their sites to warn workers and the public and joint
/Other activity has started with other operators to implement a workers directive in Hungary.
actions
Exposure The government implements precautionary actions in addition to the limit guidelines.
guidelines
I.13 Ireland
Rec.#1 & 9 All operators report having formal company policies in respect of good practice for
network rollout. Processes to communicate and provide information to the local
authority/ the public on current and future network deployment plans have been
established and the need to install more network antennas is communicated to the
public. Detailed technical and supporting deployment justifications are provided with
each application to the local authority or other regulatory body. Other information
provided includes the planning framework, potential impact to the environment/
community, technology and health information. Site images and photo montages are
also made available. Operators conduct consultation programmes or involve local
communities in the categorisation of proposed sites. In some cases a monitoring system
for auditing the information exchange process is used. Stakeholders include the
regulator and the local authorities, the public, local communities and the media.
Information flow is facilitated through one to one sessions. In most cases a company’s
standard format is used, although sometimes the information layout is adjusted to the
requirements of the people involved. Information is provided when there is a new
deployment or when it is requested by public. It is reported that stakeholders find the
information very useful.
Rec. #2 Operators share sites with other operators’ sites, tower and roof-mounted sites, other
telecommunication masts and radio installations or utilities’ facilities. In Ireland, utility
companies share their site and facilities with all mobile operators and with the police
services. It is reported that more than 70% of the sites are shared, while 3G/2G sharing
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reaches 75%. Formal processes to administer site sharing are in place and operators
expect that site sharing will increase over the next five years.
Rec. #3 Operators use alternative designs and coloured installations to reduce the visual impact
of sites. Examples include chimneys, trees, architectural building features, grain silos,
advertising signs and antenna painted t match a building façade. In some cases
operators follow local authority planning permission requirements which may include
conditions on visual design.
Rec. #4 Operators provide information on existing services/technologies: description of services,

benefits and possible impact. In some cases information on new services and possible
infrastructure requirements is also provided and education sessions are conducted to
explain to the local authority how the technology works or why the sites have to be
established in the specified locations. Sessions are conducted quarterly or when
required. It is reported that councils find these sessions very informative. Operators are
considering 3G deployments in lower frequencies which may reduce the number of base
station sites required and therefore rollout cost and time.
Rec. #5 Operators report base station compliance with European exposure limits. Emission tests
are carried out by operators as per the regulator’s standard for each new site.
Rec. #6 On average, more than 50% of sites are certified with processes in place to ensure
compliance with the EU Directive recommendations for occupational exposures. There
are also policies for company employees accessing areas close to antennas (e.g. safe
systems of work, personal monitors, audits, measurements on site) and guidelines for
third party workers (e.g. safe systems of work provided to landlords; processes which
require the power down of equipment while third parties may be in a specific area). Pre-
installation calculations and post-installation measurements are performed. Operators
report monitoring and measuring the RF exposure in public areas from sites when first
commissioned and at regular intervals subsequently. This may be due to regulatory
requirement or to respond to public concerns. One operator reports that sites are
measured at the closest point of public access.
Rec. #7 Operators have processes to address issues raised to the company at the national level
and also to address individual issues (e.g. consumer or site-specific). In some cases
responses are provided via the Irish Cellular Industry Association (ICIA). Named contact
personnel are responsible for liaison with local authorities. Complaints are handled by
EMF trained staff and manager with corporate responsibility. Complaints are dealt with
by telephone call/ email or meeting with the people involved with the compliant or
query. Response times are monitored. In some cases, a site acquisition and PR team
coordinates all responses to the public.
Rec. #8 Operators support national government research and the GSMA’s programmes and
initiatives. Research results are made available to the staff. FAQ documents are updated
and used with local authorities and public. In other cases, the results are shared
through Industry associates.

Level of There has been a small increase in the level of concern over the last 18-24 months.
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68
concern GSM Europe Recommendations have not necessarily led to the reduction of the
complaints. Health-related concerns are at a high level with an increasing trend.
Operators report that people do not want the installation near where they live. People
object at the planning and installation stages, although the situation is improving.
Codes of The EMF subgroup of ICIA has developed the “10 Commitments” 73 document, which has
practice & been agreed by all the operators in Ireland.
Audit
process
Voluntary All operators take part in industry groups to try and address EMF issues directly and
actions from consistently with the public and government. There are also landlord surveys conducted
MNOs for monitoring/ auditing purposes.
Government The government implements precautionary actions (e.g. exclusion zones for masts, in-
/Other site measurement programmes) beyond the limit guidelines and provides precautionary
actions advice on the use of mobile phones (e.g. reducing call time, advice for mobile usage by
children).
Exposure EU Recommendation (Government plans to incorporate, time scale not yet determined)
guidelines – Ref: Planning and Development Act November 2001, Telecommunications Law
I.14 Italy
Rec.#1 & 9 All operators are required to establish formal processes for communication and
information provision to the local authorities/ public on current and future network
deployment plans. Mandatory detailed technical and supporting deployment
justifications are provided with each application to the local authority or other regulatory
body. Other information provided includes the planning framework, the potential impact
on the environment, the potential impact/ benefit to the community, and technology
and health information. Computer-generated images or photo montages are sometimes
made available. Operators also conduct consultation programmes or involve local
authorities for site deployment. Other means of communication include information
sessions/ road shows, seminars, public/ media announcements, one to one sessions and
participation in public hearings when invited by local authorities. Information is usually
provided in cases of new deployments or when requested by the public/ authority. All
operators have established monitoring and documentation system for their information
exchange processes.
Rec. #2 All operators share sites and expect an increasing trend over the next five years. A
formal site sharing administration process is already in place. The majority of sharing
includes other operators’ facilities, tower site sharing, roof-mounted site sharing, other
telecommunication masts or radio installations. Although cost saving is the main reason
73
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69
for site-sharing, environmental concerns and landscape preservation are also important
reasons.
Rec. #3 Operators in Italy make use of alternative design, with the majority following specific
guidelines to lower the visual impact.
Rec. #4 Mobile operators inform planning and regulatory authorities of technological

developments on mobile telecommunications (existing and new services, benefits, and
possible impact, infrastructure and timescale requirements). Educational sessions for
site justification also take place. The frequency of these sessions depends on the
requirement of the local authority. The feedback from local communities and the general
public is considered to be very positive. The industry and the Italian regulator have
opened a consultation process for the deployment of 3G networks operating at lower
frequencies, which essentially reduces the number of sites needed.
Rec. #5 Italian national exposure guidelines are stricter than ICNIRP. Continuous monitoring is
sometimes required, in specific cases, by landlords, municipalities or regional
environmental authorities. An EMF national monitoring network has also been deployed.
Rec. #6 All operators report 100% certified sites, with processes in place to ensure compliance
with the EU Directive recommendation for occupational exposures. Before
commissioning a site, operators perform pre-installation calculations and
measurements, and regular post-installation measurements once the site is
commissioned. Post-installation measurements are mandatory in two Italian regions,
while in the other regions they are required when the EMF calculated value is higher
than 50% of the applicable limit and also in response to public concerns. All operators
have policies for their own employees when accessing areas close to antennas.
Guidelines are provided to third parties working in or around the antennas.
Rec. #7 Operators have processes in place to address issues raised at a national and individual
level. In most cases specialist staff is responsible for managing issues with local
residents. Cross-functional teams (media relations, institutional relations, safety, EMF)
may also handle the process to respond to individual enquiries. Response times are
monitored.
Rec. #8 All operators participate in corporate (group-wide) research projects, and support
government initiatives and GSMA programmes. Fondazione Ugo Bordoni (FUB), a high
culture institution participated by the Minister of Communications and by the Italian
mobile operators, publishes research results and organises seminars and meetings to
promote awareness of the results. Operators also promote communication of the studies
via conferences, web-site announcements and newsletters.

Level of The level of concern regarding health issues in Italy is considered high. Environmental
concern and aesthetic issues are at a medium level with, nationally, no significant change over
the last 18-24 months. However, according to data from Piemonte Regional
Environmental Authority (March 2006) complaints from citizens reduced by 40%.
Codes of All operators make reference to the GSME Recommendations on Network Rollout Good
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70
practice & Practice.

Audit
process
Voluntary In some cases specific risk assessments are made. A nationwide network for
actions from electromagnetic field monitoring has been deployed, provided by the Prime Minister
MNOs Decree of March 2002 (using part of the proceeds from the 3G tender) and is led by
FUB.
Government The government has implemented precautionary actions beyond the guideline limits.
/Other The FUB organises communication activities (BluBus, BluShuttle).
actions
Exposure EU Recommendation (precautionary limits) - Ref: Ministerial Decree DM381/1998; GU

guidelines No.199 “Establishment of exposure limits, attention values, and quality goals to protect
the population against electric, magnetic, and electromagnetic fields generated at
frequencies between 100 kHz and 300 GHz”, Public
Ref: Decree of the President of the Council of Ministers (08/07/2003): As a cautionary

measure to protect against any possible long-term effects that might be related to
exposure to fields at the aforementioned frequencies, the attention values of 20 V/m.
and 6V/m. are adopted in children’s playgrounds, residential dwellings, school premises,
and in areas where people are staying for 4 hours or more per day, as well as in
outdoor annexes that may be used as residential environments, such as balconies,
terraces, courtyards, but excluding roof paving.
I.15 Latvia
Rec.#1 & 9 Respondent(s) have an internal policy, which makes reference to GSME
Recommendations, for good practice for network rollout. It is a mandatory requirement
to communicate and provide information to the local authority/ the public on current
and future network deployment plans and to provide detailed technical and supporting
deployment justifications with each application to gain authorisation from local authority
or other regulatory body. Information is also provided to the Public Health Agency. The
need for base station installation is communicated to the public on a case by case basis.
Apart from technology and health related information, the operator provides photo
montages, maps, antennae data (height of placing antennae), frequency bands and
powers, directions, results of calculation/estimation etc. Consultation programmes and
processes to involve local communities in the categorisation of proposed sites are
conducted voluntarily. Other means to facilitate information flow include road shows and
seminars. Information is provided in varying formats according to need and the Public
Health Agency accepts the data provided. There are also processes in place to monitor
and document the information exchanges, although no auditing process has been
established.
Rec. #2 Respondent(s) share sites with tower and roof-mounted sites, other telecommunication
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71
masts and radio installations. All 3G sites are shared with operators’ 2G sites. Cost
saving is the main reason driving site sharing. Environmental and landscape
preservation reasons are also considered important, as site sharing is required by local
authorities. Operator reports that site sharing will increase over the next five years.
Rec. #3 It is reported that alternative designs for base station installation is implemented (e.g.
top of the water towers, TV and radio towers).
Rec. #4 Survey participant(s) report that provide information on existing and

services/technologies: description of services, benefits, possible impact, infrastructure
requirements and the timescales of development. Annual education sessions with the
local authorities are held to explain how the technology works or why the sites have to
be established in a specific location. The response varies: in some cases operator’s
efforts to educate local authorities are perceived as internal difficulties faced by the
operator rather than a means of providing information exchange.
Rec. #5 Respondent(s) report base station compliance with European exposure limits.
Rec. #6 Respondent(s) report 100% of sites are certified, with policies for their own employees
accessing areas close to antennas (e.g. workers have individual dosimeters with alarm
levels and have been advised to switch off the equipment if the need to work in a direct
beam close to an antenna). Similar guidelines are provided to third party workers (e.g.
provision of information annually about the specific risks at sites during instruction in
Occupational Safety & Health, OSH). Prior to commissioning a site, pre-installation
calculations and regular post-installation measurements are performed (in some places,
where the owners have requested).
Rec. #7 There are processes in place to address individual issues (e.g. consumer or site-
specific). These issues are handled by OSH and PR personnel.
Rec. #8 GSMA programmes and initiatives on research studies are supported.

Level of Public concern has remained almost the same over the last 18-24 months. Health and
concern environmental concerns are at a medium level. Aesthetic concerns are at a low level,
but increasing.
Codes of An operator reports that the GSM Europe Recommendations are used as a reference for
practice & its network rollout.
Audit
process
Voluntary Operators cooperate with the academic society to include information about modern
actions from communication using cell-phones in university books.
MNOs
Government The government provides precautionary advice on the use of mobile phones (e.g.
/Other reducing call time, advice for mobile usage by children).
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72
actions
Exposure EU Recommendation – Ref: LVS (Latvian Standard) ENV 50166 1995

guidelines
I.16 Lithuania
Rec.#1 & 9 It is reported that no national policy is in place for network rollout. One operator reports
that it has established processes to communicate and provide information to the local
authority/ the public on its current and future network deployment plans. The need to
install more network antennas is communicated to the public voluntarily on a case by
case basis. The provision of detailed technical and supporting deployment justifications
with each application is mandatory to gain authorisation from local authorities or other
regulatory bodies. Other information provided includes an assessment on potential
impact to the environment and the community, technology and health information.
Consultation programmes and the involvement of local communities in the
categorisation of proposed sites are voluntary activities by operator undertaken as
needed. When there are new deployments or when information is requested, it is
provided by means of public/ media announcements, letters to nearby neighbours and
one to one sessions. Information is provided in different formats according to the
requirements. There is no process to monitor the information exchange process or
internal auditing of the results.
Rec. #2 Operators share sites with tower and roof-mounted sites and other telecommunication
masts. Cost is the most important factor for site sharing, although local authorities may
require sites to be shared. Site sharing is administered by a formal process. It is
reported that site sharing will increase over the next five years.
Rec. #3 One operator makes use of alternative designs, although there is no reference to
specific guidelines.

description of services, benefits, possible impact and any data required for public
consultation.
Rec. #5 It is reported that base station comply with national exposure limits. Lithuanian
guidelines (10uW/cm2) which are about 30 times more stringent than European
guidelines.
Rec. #6 Respondent(s) report that 100% sites are certified. Policies are in place its own
employees accessing areas close to antennas (e.g. switch off or reduce power while
working close to antennas). Similar policies are followed for third party workers. Prior to
the commissioning of a site, the operator performs pre-installation calculations followed
by post-installation measurements. Such activities are regulatory requirements and may
be carried out in response to public or other concern.
Rec. #7 Operators have policies in place to address individual issues (e.g. consumer or site-
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73
specific). In 90% of cases, technology divisions provide info to PR department in order

that they can respond to queries. In the remaining cases the issues are addressed by
the technology divisions directly. These processes are monitored for response times.
Rec. #8 An operator participates in national university research programmes into radiation and
EMF levels. The operator has informed the authorities and published newspaper articles
to disseminate the results of the studies.

Level of The level of public concern is unchanged over the last 18-24 months. Health related and
concern environmental concerns are at a low level, with an increasing trend. No concerns have
been raised related to technology and aesthetic issues.

practice &
Audit
process
Voluntary Education sessions are held to explain technologies to local authorities and why sites
actions from have to be established in specific locations. These sessions have been conducted several
MNOs times, with positive effect.
Government The government implements precautionary actions beyond the limit guidelines (e.g.
/Other exclusion zones for masts, in-site measurement programmes).
actions
Exposure National (Not based on ICNIRP)

guidelines
a. Public - Ref: HN 81 (1998) “Base stations of mobile cellular communications”
b. Public and Occupational – Ref: HN 80 (2000) “Electromagnetic field at work and at

living places. Normative values and measuring requirements in 10 kHz - 300 GHz”,
based on EU Recommendation
I.17 Luxembourg

Exposure National (stricter limits than EU Recommendation) – Ref: “Standards regarding non-
guidelines ionising radiation due to cellular mobile telephony” issued by the Environment Ministry
and the Labour and Employment Ministry (http://www.senat.fr/rap/r02-052/r02-
05237.html). This document was made legally binding by the decree, authorising the
settlement mobile telephone networks. It applies to frequencies in the range from 10
kHz - 300 GHz and is valid for the public.
The Recommendation ITM-CL 179.4 (http://www.itm.lu/securite-sante-ss/conditions-

types/cl179-4.pdf) that has been issued by the Government of Luxembourg is not
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74
legally binding. It applies to frequencies in the range from 10 kHz to 300 GHz, is valid
for the public and also does not base on the ICNIRP limits. Luxembourg has applied
stricter limits than those laid down in the Council Recommendation 1999/519/EC. The
limits of the 1999/519/EC are valid for occupational exposure. No regional variations are
reported regarding protection of the public against Electromagnetic fields. However, the
administration communales (local administrations) have the authority to ignore the
national standards or to apply stricter limits for public exposure to electromagnetic
fields.
I.18 Malta
Rec.#1 & 9 In Malta, operators have processes to communicate and provide information to the local
authority/ the public on current and future network deployment plans. Operators also
communicate the need for more antenna installations and technical and supporting
deployment justifications with each application to the local authority or other regulatory
body. Technical operating information on the construction of each site is mainly
provided to the regulator. Other information includes the description of the proposed
site including computer generated images or photo montages. The format and the
frequency of the information provided varies according to the project or persons
involved.
Rec. #2 Respondent(s) share sites in various ways: tower and roof-mounted site-sharing and
utility’s facility sharing. Site sharing varies across the operators, but may reach 30%,
while all 3G sites are shared with 2G sites. It is reported that site sharing is expected to
remain at about the same over the next five years and probably increase.
Rec. #3 In Malta, alternative designs are used to reduce visual intrusion.
Rec. #4 Information on public consultation is provided and is some case education sessions are
conducted with the local authority to explain how the technology works or why the sites
have to be established in the specified locations. Feedback is generally very good.
Rec. #5 Operators report base station compliance with national exposure limits.
Rec. #6 On average, 90% of sites across the operators are certified. Processes to ensure
compliance with the EU Directive for occupational exposures are in place. Operators
have policies for own employees accessing areas close to antennas. Post-measurements
following site commissioning are also performed, as a regulatory requirement and in
response to public concerns.
Rec. #7 Operators have established procedures to address individual EMF related complaints/
enquiries (e.g. consumer or site-specific) and there are named contact personnel for
liaison with local authorities. In some cases telephone hotlines and web-sites that
receive enquiries and dispatch information are used.
Rec. #8 One operator supports national government research studies. Interested individuals are
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75
informed of the research results.

Level of The level of concern regarding network rollout over the last 18-24 months has remained
concern the same. Health issues are a high concern, which have increased over the period.
Environmental and aesthetic concerns are of medium/ low level. The operator reports
that actions taken under the GSME Recommendations have led to the reduction in the
number of the complaints.
Other concerns include property value reduction for the neighbouring dwellings.
Codes of One operator makes reference to GSM Europe Recommendations and in other cases, a
practice & combination of mandatory requirements and national policies apply. The regulator,
Audit periodically, carries out audits and publishes the results.
process
Voluntary Direct engagement with interested parties. Discussions with Malta Environment and
actions from Planning Authority (MEPA) to simplify process of the review for planning applications.
MNOs
Government During 2006 over 80 sites were audited by the regulator and these included GSM900,
/Other GSM1800 and 3G base stations. The regulator also audited broadcasting transmitters
actions and other sources of EMF such as microwave links and public land mobile transmitters.
The results are available on the regulator’s web site. 74 The regulator liaises annually
with media to publicise its EMF audit results.
Exposure EU Recommendation (no legislation) – Ref: Report on Recommendations for limiting

guidelines human exposure to time-varying electric, magnetic and electromagnetic fields in the
frequency range from 0 Hz to 300 GHz (25/08/2000)
I.19 The Netherlands

Rec.#1 & 9 All operators report having a formal company and national policy for good practice for
network rollout. All network operators provide information for new antenna installation.
In most cases detailed technical and supporting deployment justifications are provided
with each application to the local authority or other regulatory body. The application is
complemented with consultation programmes and the involvement of local
communities. Information exchange between stakeholders (local authority, regulator,
public community, national antenna bureau) is part of the national antenna policy
(National Antenna Covenant). The whole framework of the Antenna Covenant is audited
once a year by an independent party. A monitoring and documentation system for the
information exchange process is in place by all operators and audited results are
published. The results of the auditing of this process are published. Information flow is
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76
facilitated via consultation processes, sessions/ road shows (where health issues are
addressed), seminars, one to one communication and letters to nearby residents.
Information provided includes details of the planning framework, potential impact to the
environment and impact/ benefit for the community, technology and health related.
Photo montages are also made available.
Rec. #2 All operators report site sharing with other operators’ facilities, tower site sharing, roof-
mounted site sharing other telecommunication masts, radio installations and utility
facilities. A formal administration procedure is in place. On average 76% of sites share
with existing infrastructure. 3G site sharing is near to 85%. It is believed from the
operators that these percentages will remain the same or probably increase over the
next five years.
Rec. #3 Most operators report the use of alternative designs to reduce the visual impact of sites.
Rec. #4 The majority of operators provide information on existing and new

services/technologies: description of services, benefits, possible infrastructure
requirements, and timescales of deployment and public consultation information. All
operators conduct educational sessions to explain to the local authority how the
technology works or why the sites have to be deployed in specified locations. The
response from the public has been positive and that the sessions are considered to be
informative.
Rec. #5 All operators report base station compliance with European exposure guidelines and
have processes in place to ensure compliance with EU Directive for occupational
exposure. Pre-installation calculations and post-commission measurements are also
performed.
Rec. #6 Measurements are performed in response to public concerns. All operators have policies
for their own employees when accessing areas close to antennas and guidelines for third
party workers.
Rec. #7 All operators report having processes in place to handle EMF complaints/ inquiries at a
national level, through the Trade Association (MoNet) or in response to individual cases
(e.g. consumer or site-specific). These processes are managed by specialist staff. Staff
interacts with local residents and there are named contact personnel for liaison with
local authorities. Telephone hotlines and websites are used to handle enquiries and
dispatch information. MoNet, which represents network operators, provides coordination
of information exchange. The response times of these processes are monitored.
Rec. #8 Operators participate in group-wide corporate research and governmental research

projects. They also support GSMA programmes and initiatives. Research studies are
communicated to the public by operators or national authorities.

Level of The level of concern related to network rollout in the Netherlands has remained the
concern same over the last 18-24 months. Health concerns are at a high/ medium level.
Environmental and aesthetic concerns are at a stable medium/ low level. It is reported
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77
that operators’ activities related to GSME Recommendations have reduced the number
of complaints and enquiries overall.
There are also 3G-specific concerns and concerns about long term exposure.
Codes of The National Antenna Covenant 75 framework is audited once a year by an independent
practice & party and a report is sent to the national parliament. The performance of operators has
Audit been good over the years. One operator makes reference to GSM Europe
process Recommendations.
Voluntary Operators offer education sessions. The course is called PATO and is open to
actions from municipality officials.
MNOs
Government National government and technical universities participate in the PATO course (see
/Other above). Further information can be found at http://www.gr.nl/.
actions
Exposure EU Recommendation (no plans for legislation) – Ref: Letter of the Ministry of Housing,
guidelines Spatial Planning and the Environment on overhead power lines (03/10/2005), Public
I.20 Poland
Rec.#1 & 9 Respondent(s) have a formal company and national policy for good practice for network
rollout, which makes reference to GSME Recommendations. It is a mandatory
requirement to have formal process to communicate and provide information to the
local authority/ the public on current and future network deployment plans and explain
to the public the need to install more network antennas. Detailed technical and
supporting deployment justifications are provided with each application to a local
authority or other regulatory body. Other information provided includes the potential
impact on the environment, impact/ benefit to community and health related
information. Letters to nearby residents are distributed to facilitate information flow.
The information format varies depending on the project and the people involved. In
general information is provided when there is a new deployment or when it is requested
by the public or by a local authority. A monitoring and documentation process for the
exchange of information is in place, although the process is not audited.
Rec. #2 Site sharing is implemented with other operators’ facilities, tower site and roof-mounted
sites, transmission equipment shelters, antennas, other telecommunications masts and
radio installations. More than 85% of 3G sites are shared with 2G sites. The main
reasons for site-sharing are cost saving and landscape preservation. A formal process is
in place to facilitate the administration of site sharing. Respondent(s) report that the
percentage of shared sites will increase over the next five years.
Rec. #3 Operator(s) report use of alternative designs.
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78
Rec. #4 Annual educational sessions are contacted to explain to the local authority how the
technology works or why the sites have to be established in specific locations.
Rec. #5 Respondent(s) report base station compliance with National exposure limits (which are
stricter than ICNIRP exposure limits). Processes have been established to ensure
compliance with the EU Directive for occupational exposures.
Rec. #6 100% of sites are certified. Policies for the company’s own employees accessing areas
close to antennas are in place and guidelines for third parties e.g. painters or
construction workers working in or around antennas are provided (e.g. code of conduct
for subcontractor). Pre-installation calculations and post-installation measurements are
performed. Operator(s) monitor/ measure the RF exposure in public areas when sites
are first commissioned and at regular intervals subsequently in accordance with legal
requirements.
Rec. #7 Company procedures for handling complaints and enquiries are established. Specialist
staff is responsible for communication and managing issues with local residents.
Rec. #8 Corporate (group-wide) research programmes are supported. The studies conclusions
are presented in meetings with local residents.

Level of It is reported that the level of concern has increased over the last 18-24 months. Health
concern concerns are at a high level. Environmental and aesthetic concerns are in medium level.
Other concerns reported include a drop in property values.
Codes of An operator makes reference to the GSM Europe Recommendations.

practice &
Audit
process
Voluntary Consultation programmes are conducted on a case by case basis and local communities
actions from may be involved in the categorisation of proposed sites.
MNOs
Government There are agreed national procedures with requirements for deploying base stations
/Other which are required by national law.
actions
Exposure National (Law, not based on ICNIRP)

guidelines
a. Ref: Ordinance of the Polish Ministry of Labour and Social Policy (29/11/2002),
Journal of Law No 217/2002 para 1833, Occupational
b. Ref: Ordinance of Ministry of Environment (30/10/2003); Official Journal No

192/2003, pos. 1883– Public & Environmental
.
79
I.21 Portugal
Rec.#1 & 9 Respondent(s) reported having a formal company policy for good practice for network
rollout, which refers to GSME Recommendations. It is mandatory to communicate and
provide information to the local authority/ the public on current and future network
deployment plans. The operators always communicate to the public the need to install
more network antennas. Detailed technical and supporting deployment justifications are
provided with each application to gain authorisation from the local authority or other
regulatory body, which are mandatory requirements. In some cases the operator
conducts consultation programmes or involves local communities in the categorisation
of proposed sites. It is also required for the operator to have a monitoring and
documentation system for information exchange processes, which is audited on a
voluntary basis. As well as local authorities and communities and the regulator,
landlords are also involved in the information exchange process. Information flow is
facilitated by sessions/ road shows and seminars, letters and one to one sessions. The
information is provided in the company’s standard format, on an annual basis or when it
is requested by a public or local authority or when there is a new deployment.
Information includes details of the planning framework, the potential impact on
environment/ benefit to community, technology and health information, and a
description of the proposed site including computer generated images or photo
montages.
Rec. #2 Operator(s) share sites with other operators’ facilities, tower and roof-mounted sites,
antennas and other telecommunications masts. 90% of 3G sites are shared with 2G
sites. A formal administration process for site sharing is in place. Site sharing is
implemented to achieve cost savings, to meet regulatory and licensing requirements,
and also to address concerns regarding environmental and landscape preservation. It is
reported that site sharing will increase over the next five years.
Rec. #3 Operator(s) report the use of alternative designs and that it follows specific guidelines in
line with corporate (group-wide) network deployment policies.

description of services, benefits, possible impact and public consultation information.
Educational sessions are held, when required, to explain to the local authority how
technology works or why sites have to be established in specific locations. The
information provided is generally appreciated by the recipients. An operator is
considering the deployment of 3G in 900 MHz to reduce the required number of sites.
Rec. #5 Respondent(s) report base station compliance with European exposure limits.
Rec. #6 It is reported that 60% of sites are certified. Processes are in place to ensure
compliance with the EU Directive for occupational exposure. Policies have been
implemented for the company’s own employees when accessing areas close to antennas
and guidelines are provided for third parties e.g. painters or construction workers
working in or around antennas. Regular RF exposure measurements are performed as
part of company’s communication policy and to comply with regulatory requirements.
.
80
Measurements are also performed in response to public concerns.
Rec. #7 There are processes in place to address issues raised to the company at a national level
and to address individual issues (e.g. consumer or site-specific). Operator(s) employ
specialist staff to manage complaints and cooperate with local residents. Named contact
personnel are available for liaison with local authorities. Telephone hotlines and web-
sites that receive enquiries and dispatch information are in place.
Rec. #8 There are cases where operators support corporate (group-wide) research studies.
Respondent(s) also sponsor the Independent EMF Monitoring - Project monIT which was
developed by the Telecommunications Institute. This project aims to provide the general
public with all the relevant information about levels of exposure to electromagnetic
fields, in particular those generated by telecommunications antennas. In addition to
publishing the results of systematic monitoring at various public places around Portugal
and specific technical information, Project monIT provides a range of scientifically
accurate information on its website about electromagnetic fields emitted by mobile
telecommunications systems, written in plain language.

Level of It is reported that the level of concern has been stable over the last 18-24 months,
concern although it is characterised as being very variable and dependant on particular network
rollouts. Media coverage on EMF issues may also impact the level of public concern. An
operator reports that the implementation of GSME Recommendations has reduced the
number of complaints. Health and environmental concerns are at a medium level.
It is reported that level of concern increases when there is negative media coverage on
EMF.
Codes of Operators make use of the “Code of Conduct and Good Practice for the installation of
practice & the equipment which generates electromagnetic fields”. 76 . For one of the operators in
Audit Portugal, a corporate (group-wide) auditing survey was conducted.
process
Voluntary One operator organises seminars in local municipalities to inform interested parties
actions from about the results of remote EMF measurements in the municipality. An independent
MNOs Field Monitoring Project - Project Monit is also sponsored. The project aims to provide
the general public with all the relevant information about levels of exposure to
electromagnetic fields - leaflets and brochures are available.
Government The government provides precautionary advice on the use of mobile phones (e.g.
/Other reducing call time, advice for mobile usage by children).
actions
Exposure EU Recommendation (legislation) – Ref: Portaria No.1421/2004 (23/11/2004)

guidelines
76
http://www.anacom.pt/template20.jsp?categoryId=40989&contentId=59099
.
81
I.22 Romania
Rec.#1 & 9 Operators in Romania have processes in place to communicate and provide information
to the local authority/ the public on current and future network deployment plans. In
some cases GSME Recommendations are used as reference. The need to install more
network antennas is communicated to the public on a case by case basis. It is a
mandatory requirement to provide technical operating information on the construction
of each site to the local authority. Details of the planning framework, the potential
impact on the environment/ benefit to the community, health information and a
description of the proposed site, including computer generated images or photo
montages, are also made available. Stakeholders include the regulator, the public and
the local community. Information flow is facilitated with consultation processes,
information sessions/ road shows, public/ media announcements and one to one
sessions. Other means include EMF hotlines, brochures for the public, files with specific
information for landlords, brochures for employees and reports to public health offices.
A company standard format is used in some cases. There are cases where the
information is provided on a monthly basis or when there is a new deployment or when
it is requested by the public. Feedback is rather positive, as regulators are satisfied and
so are most of the local authorities.
Rec. #2 All operators share sites with other operators’ facilities, tower and roof-mounted sites,
transmission equipment shelters, antennas and other telecommunication masts. 90% -
100% of 3G sites share with 2G sites. Cost saving is the main reason for site sharing. A
formal process is in place to administer the site sharing process. All operators report
that site sharing is expected to increase over the next five years.
Rec. #3 All operators report the use of alternative designs. Examples mainly include artificial
trees and antennas integrated with building architecture. In some cases specific
guidelines are followed (e.g. use of smaller antennas if possible; use of closets for
equipment on the last floor rather than cabinets on roof top, use of existing poles, etc.).

services, benefits, possible impact. In some cases additional information is also made
available such as possible infrastructure requirements and timescales of development.
One operator also reports that, twice a year, education sessions are conducted to
explain to the local authorities how the technology works or why the sites have to be
established in specific locations. These sessions receive relatively positive feedback. All
operators are considering the deployment of 3G in lower frequency bands to reduce the
requirements for base stations.
Rec. #5 All operators report base station compliance with European exposure limits.
Rec. #6 All operators report 100% certified sites, with processes in place to ensure compliance
with the EU Directive for occupational exposures. They have policies for their own
employees when accessing areas close to antennas. In some cases guidelines for third
parties e.g. painters or construction workers working in or around antennas are
provided. Operators perform pre-installation calculations or post-installation
.
82
measurements in response to the concerns of the public or others.
Rec. #7 All operators have internal processes to address individual issues (e.g. consumer or
site-specific). For example, one operator provides an official response which includes
EMF related information, a government published brochure on EMF and mobile
telephony, the WHO Fact Sheet No. 304/2006 and offers to make field measurements
through a third party. There are named contact personnel for liaison with local
authorities and telephone hotlines and web-sites that receive enquiries and dispatch
information. In some cases specialist staff is employed to manage issues and
communications with local residents. Response times are monitored internally.
Rec. #8 Operators support company (group-wide corporate) research. GSMA programmes and
initiatives are also supported by some operators. Operators make independent research
results, published in peer-reviewed scientific publications, available to the public
through media announcements.

Level of The overall level of concern in Romania is lower than it was when it peaked, two years
concern ago. At that time there was a lot of negative media coverage. Over the last 6 to 9
months negative media articles have reduced and very few sites have been rejected/
delayed as a result of people’s concern on EMF issues. Central media, central authorities
as well as the majority of local authorities are well informed reducing the risk of
increasing concern. GSM Europe Recommendations have not necessarily reduced the
level of complaints. The main concerns are health-related. Environmental, aesthetic and
technology concerns are either non-existent or at low levels.
Operators encounter opposition from the general public in some cases and the local
authorities where the public opinion is strong enough to put pressure on them. Most of
the complaints are caused by the fact that people draw their information from
newspaper articles and hearsay and are reluctant to acknowledge information provided
by operators, as they consider that operators influence the research or the public health
offices. People are very unresponsive to any information provided by the operators
(using objective sources) and prefer to trust the media or hearsay. It is reported also
that EMF concerns are relatively less in locations where base stations are already
installed, however there has been a sharp increase over the last year, following several
newspaper articles and TV shows that stated that GSM antennas cause cancer and
numerous health problems.
Codes of One operator makes reference to GSM Europe Recommendations.

practice &
Audit
process
Voluntary Operators participate in public conferences and round tables on EMF and mobile
actions from telephony and they provide media announcements when new research is published. One
MNOs operator has issued two brochures with information about EMF: one official brochure for
the general public; the other for internal use. The operator deals with each individual
complaint or inquiry and an EMF hotline has been set-up to deal with questions. Base
.
83
station sites are marked with EMF specific signs. The operator has a company EMF
policy which deals with internal and external communication, base station site
compliance, terminal compliance, management and reporting. Meetings are planned
with local authorities to inform them on research in this domain and on the future
development of the network in their area. There are coordinated actions with other
operators and the national regulator to move towards a country-wide EMF measurement
campaign from which the results will be published on a government’s website. The
operators’ intention is to increase the available information sources in shops and
websites and educate all employees that make direct contact with customers.
Government The government publishes a brochure on EMF and mobile telephony.

/Other
actions
Exposure EU Recommendation – Ref: Ordinance No.1193 (29/09/2006); No.895 (03/11/2006)

guidelines
I.23 Slovakia
Rec.#1 & 9 Operators communicate the need to install more network antennas to the public. It is a
mandatory requirement to provide detailed technical and supporting deployment
justifications with each application to local authorities or other regulatory bodies.
Operators conduct consultation programmes or involve local communities in the
categorisation of proposed sites. In some cases operators monitor the information
exchange process but auditing is not performed. The main stakeholders include local
authorities, the regulator, public or local community, owners and neighbours of a
building or land where the site is to be built. The process is facilitated by public/ media
announcements, one to one sessions and letters to nearby neighbours. The format of
the information varies depending on project and persons involved. Common information
includes technology and health information together with descriptions of the proposed
sites including computer generated images or photomontages. Some operators provide
details of the planning framework and an assessment of potential impact to the
community and the environment. Information is provided only for a new development.
Rec. #2 All operators report tower site sharing and occasionally sharing with other
telecommunications masts, antennas and utility’s facilities, mainly for cost saving
reasons. All 3G sites are shared with 2G sites. It is reported that site sharing will
increase over the next five years.
Rec. #3 All operators report use of alternative designs to minimise visual impact. One operator
follows an internal procedure (ISO-14001) to reduce visual impact by means of coloured
installations, masking, reduced number of antennas by using dual or tri-band antennas.

services, benefits, and possible impact and infrastructure requirements. In some cases
educational sessions are held to explain to the local authority how the technology works
.
84
or why the sites have to be established in the specified locations. Feedback is that some
sites are controversial, some of them are accepted, but there are cases where part of a
local community is strongly against any position or information.
Rec. #5 All operators report base station compliance with national exposure limits.
Rec. #6 All operators report 100% certified sites. In most cases operators perform pre-
installation calculations and measurements and post-installation measurements. All
operators monitor and measure RF exposure from their sites in public areas. In addition
to these obligatory measurements, operators also undertake measurements when
requested by the community living near to sites.
Rec. #7 Processes are in place to address individual issues (e.g. consumer or site-specific).
Operators, depending on the type of complaint/ enquiry, may send information, conduct
educational sessions, provide explanations or perform additional measurements. The
management of the process is handled by named contact personnel who liaise with local
authorities. Specialist staff is employed to communicate and manage issues with local
residents. Some operators have telephone hotlines and web-sites that receive enquiries
and dispatch information.
Rec. #8 No research studies have been initiated: hence there is no support from operators.

Level of It is reported that the level of concern has remained about the same over the last 18-24
concern months. GSME Recommendations have not necessarily led to the reduction of the
complaints. Health concerns are at a high/ medium level and have probably increased
during the period. Environmental and aesthetic concerns are at a medium/ low level
with no significant change over the last two years. No major concerns regarding
technology.
It is also reported that in some cases communication with public is difficult, as local
communities are not willing to participate in discussions.

practice &
Audit
process
Voluntary In some cases, operators provide WHO documents translated into Slovak with the
actions from format depending on the type of project (slide presentation and software model of EMF
MNOs simulation). Other information includes details of EMF, Specific Absorption Rate (SAR).
This information is available on web sites, via hot line, points of sales and touch
screens. Occasionally, upon a special request, additional shielding/grounding is
implemented or EMF measurements are conducted.
Government EMF levels at sites are measured by an independent body (State office for public health)
/Other after installation and then after every three year as required by law.
actions
.
85
Exposure EU Recommendation – Ref: Decree No 123/1993 (Coll.) on the protection of health from
guidelines the harmful effects of electromagnetic fields, Public & Occupational
I.24 Slovenia
Rec.#1 & 9 Respondent(s) follow a national policy for good practice for network rollout. On a
voluntary basis, operator(s) provide information to the local authority/ the public on
current and future network deployment plans. Operator(s) also conduct consultation
programmes or involves local communities in the categorisation of proposed sites. The
need to install more base stations is communicated on a case by case basis. Educational
sessions to explain to the local authority how the technology works or why the sites
have to be established in specific locations are conducted at regular intervals upon
request by local communities. Detailed technical and supporting deployment
justifications with each application to gain authorisation from the local authority or other
regulatory body is a mandatory requirement. The information is also provided to the
Ministry of Environment and Spatial Planning. Other information provided includes
details of the planning framework and a description of the proposed site including
computer generated images or photomontages. In order to facilitate the information
flow, operator(s) usually holds one to one sessions.
Rec. #2 Operator(s) share sites with tower and roof-mounted sites, other telecommunication
masts and radio installations, following specific site-sharing administration processes. It
is believed that site sharing will increase over the next five years.
Rec. #3 Respondent(s) report making use of alternative designs (e.g. artificial trees, advertising
signs) and coloured installations to reduce the visual impact of sites.
Rec. #4 Information on existing and new services/technologies is provided: description of

services, benefits, possible impact. The operator is considering the deployment of its 3G
network at lower frequencies (resulting in fewer base stations), although there are
regulatory and technical issues to be addressed.
Rec. #5 Respondent(s) report base station compliance with national guideline limits.
Rec. #6 100% of sites are certified. Processes are in place to ensure compliance with the EU
Directive for occupational exposures. Pre-installation calculations and post-installation
measurements are performed. This is a regulatory requirement and operator(s) also
perform spot-measurements in response to public or other concerns.
Rec. #7 There are processes in place to address individual issues (e.g. consumer or site-
specific). A PR team and network employees prepare case by case answers.
Rec. #8 GSMA programmes and initiatives and corporate (group-wide) projects are supported.
Project Forum EMS publishes brochures and a magazine informing the public about the
operation of base stations, effects on environment and health related concerns. The
results of these programmes are used as feedback for internal planning and roll-out
.
86
processes.

Level of It is reported that the level of concern has been stable over the last 18-24 months.
concern Health related concerns are at a high level with an increasing trend. Environmental and
aesthetic enquiries are at a low/ medium level and stable.
One of the issues that operators are facing during network deployment is public concern
regarding the vicinity of base station. In general, the public is against the deployment of
base stations (cited by operators as NIMBY 77 and NIMET 78 effects).
Codes of A combination of mandatory requirements and national policies apply. The EMS forum in
practice & Slovenia provides EMR measurements free of charge to local municipalities.
Audit
process
Voluntary An operator has recommended that a centralised register of all EU registered and
actions from authorised EMR consultants and organisations providing EMR measurements should be
MNOs published. In general the operator follows corporate activities (group-wide) and
programmes.
Government Actions in Slovenia are coordinated by a national agency for telecommunications (APEK)
/Other and non government organization (forum EMS). The government implements
actions precautionary actions beyond limit guidelines (e.g. exclusion zones for masts, in-situ
measurement programmes) and provides precautionary advice on the use of mobile
phones (e.g. reducing call time, advice for mobile usage by children).
Exposure National (stricter limits than EU Recommendation) - Ref: Decree on electromagnetic

guidelines radiation in natural and living environment (OG 70/96), for natural and living
environment; Regulations “SIST ENV 50166-1, Human exposure to electromagnetic
fields Low-frequency (0 Hz to 10 kHz)” and “SIST ENV 50166-2, Human exposure to
electromagnetic fields High-frequency (10 Hz to 300 GHz)”, for workplaces. The limits
are below those of the Recommendation 1999/519/EC (and, because the decree is valid
only for the public, also below ICNIRP).
I.25 Spain
Rec.#1 & 9 Operators report that formal policies, at a company and national level for good practice
for network rollout are in place. Operators communicate and provide information to the
local authority/ the public on current and future network deployment plans. Detailed
technical and supporting deployment justifications with each application to gain
authorisation from local authority or other regulatory body are always provided.
77
NIMBY: Not In My Back Yard
78
NIMET: Not In My Election Time
.
87
Operators conduct consultation programmes or involve local communities in the

categorisation of proposed sites. Other information provided includes details of the
planning framework, potential impact to the environment/ community, technology and
health information. There is some audited monitoring and documentation of the
information exchange process. The main stakeholders of the information exchange are
the local authority, the regulator and the public/ local community. Information flow is
facilitated via sessions/ road shows, seminars and public/ media announcements. The
operator uses a company standard format to provide information annually or when
there is new deployment.
transmissions equipment shelters, antennas, other telecommunication masts and radio
installations. 65% of 3G sites share with 2G sites. Environmental concerns and
landscape preservation are the main reasons for site sharing. A formal administration
process is in place. It is reported that site sharing will increase over the next five years.
Rec. #3 Operators use alternative designs to minimise visual intrusion, following specific
guidelines (Spanish Mobile Phone companies’ responsible deployment code).

services, benefits, possible impact, possible infrastructure requirements and timescales
of deployment. Every two months, education sessions are held to explain to the local
authority how the technology works or why the sites have to be established in the
specific locations, with a very positive feedback from the audience.
Rec. #5 Operators report base station compliance with European exposure limits (in addition to
local and regional requirements.
Rec. #6 Operators report that 100% of sites are certified with processes in place to ensure
compliance with the EU Directive for occupational exposures. Operators also have
policies for their own employees when accessing areas close to antennas and provide
guidelines for third parties e.g. painters or construction workers working in or around
antennas. In order to commission a site, operators perform pre-installation calculations
and measurements, post-installation measurements and repeat measurements
regularly. This is part of the company’s communication policy and in accordance to
regulatory requirements and in response to public concerns.
Rec. #7 Processes are in place to address issues raised to the operators at the national level, to
address issues through the national Trade Association and to address individual issues
(e.g. consumer or site-specific). The processes are managed by specialist staff. There
are named contact personnel for liaison with local authorities and telephone hotlines and
web-sites that receive enquiries and dispatch information. The established Trade
Association representing network operators provides coordination of information
exchange.
Rec. #8 One operator supports corporate (group-wide) research studies. Other operators
support national level programmes and GSMA projects and initiatives. Results are
provided to local authorities and to the public.
.
88
Level of It is reported that the level of concern in Spain is unchanged over the last 18-24
concern months. GSME Recommendations have not necessarily reduced the level of complaints.
Health concerns are at a high level with an increasing trend. Environmental concerns
are at a medium level.
It is reported that base station installations on residential rooftops are becoming a big
challenge for operators because landlords are afraid of possible negative health effects.
There are cases where an operator has contacted the landlords of 25 buildings in order
to install one base station. This situation is not expected to improve. Operators also
report that the main problem to deploying a network in Spain is the lack of building
permits from municipalities.
Codes of One operator carries out a survey on its network rollout policy in local communities
practice & every two years. Results are considered fairly positive. The Spanish Industry Ministry is
Audit going to develop an EMF monitoring network in Spain (in 2007).
process
Voluntary Operators communicate the need to install more network antennas on a voluntary basis
actions from to the public.
MNOs
Government The government implements precautionary actions beyond limit guidelines (e.g.
/Other exclusion zones for masts, on-site measurement programmes). Some additional
actions information can be found at http://www.todocancer.com.
Exposure EU Recommendation – Ref: Royal Decree 1066/2001; Ministerial Order CTE/23/2002

guidelines
I.26 Sweden
Rec.#1 & 9 Operators have a national policy for good practice for network rollout. All operators
make reference to GSME Recommendations. A formal process to communicate and
provide information to the local authority/ the public on current and future network
deployment plans is followed on a case-by-case basis. Operators also communicate the
need to install more network antennas to the public. Other information provided
includes details of the planning framework, technology and health information and a
description of the proposed site. Operators conduct a consultation programme or involve
local communities in the categorisation of proposed sites, if requested computer
generated images or photo montages. Information flow is facilitated by sessions/ road
shows, seminars, public/ media announcements, letters to nearby residents and one to
one sessions. Information is provided when there is a deployment or when it is
requested by the public. Varying formats are used depending on the project.
Rec. #2 Operators share sites with other operators’ facilities, tower sites, transmissions
equipment shelters, other telecommunication masts and radio installations, following a
formal administration process. Operators share sites, mainly, for cost saving,
.
89
environmental and landscape preservation reasons. On average 85% of 3G sites are

shared with 2G sites. All operators report that site sharing will increase over the next
five years.
Rec. #3 Operators follow specific guidelines for alternative designs to reduce visual site impact
(Recommendations/ Handbook from The Swedish Association of Local Authorities and
Regions).
Rec. #4 It is reported that operators provide information on existing and new

services/technologies: description of services, benefits, possible impact, infrastructure
requirements and timescales of the deployment. Educational sessions are held upon
request to explain to the local authority how the technology works or why the sites have
to be established in the specified location. The feedback from these sessions is quite
positive. All operators are considering deploying 3G in lower frequencies to reduce the
required number of sites.
Rec. #5 Operators report base station compliance with European exposure limits.
Rec. #6 90% of operators’ sites are certified. Operators report to have policies for their own
employees when accessing areas close to antennas and they provide guidelines for third
parties e.g. painters or construction workers working in or around antennas (e.g. a fact
sheet regarding work on rooftop with base station antennas). Prior to the
commissioning of a site, operators perform pre-installation calculations and
measurements and post-installation measurements, mainly in response to public or
other concerns.
Rec. #7 All operators address issues raised to the company at the national level, raised through
the national Trade Association (Mobiltelebranschen) and individual issues (e.g.
consumer or site-specific). Specialist staff is employed to manage the process. There
are also named contact personnel for liaison with local authorities, telephone hotlines
and web-sites that receive enquiries and dispatch information. The established Trade
Association representing network operators provides coordination of information
exchange.
Rec. #8 Some operators support group-wide corporate research programmes, national studies
and individual projects. GSMA programmes and initiatives are also supported.

Level of All operators report that the level of complaints has decreased over the last 18-24
concern months. Operators’ activities related to GSME Recommendations and less building
permission applications are a main reason for this reduction. Health concerns are at a
medium level with a decreasing trend. Environmental and aesthetic concerns are at a
low level.
Codes of Operators have agreed the “Nine Commitments” national procedures and requirements
practice & for deploying base station facilities.
Audit
process
.
90
Voluntary Operators and Mobiltelebranschen together with the Swedish Radiation Protection
actions from Authority, scientists and some activist groups have participated in transparency forums
MNOs and seminars.
Government The Swedish Radiation Protection Authority (SSI) has issued general advice on the use
/Other of mobile phones. Use of hands-free device, Keep the mobile phone away from the body
actions and making calls then good coverage.
Exposure EU Recommendation (no plans for legislation, apply precautionary principle) – Ref: In
guidelines 2002 the Swedish Radiation Protection Authority (SSI) issued general advice on
limitation of exposure of the general public to electromagnetic fields in agreement with
the EU Recommendation.
I.27 Switzerland
Rec.#1 & 9 Operators have company and national policies for good practice for network rollout. The
need to install more network antennas is communicated, voluntarily, to the public by
the operators. A consultation process with local communities together with detailed
technical and supporting deployment justifications with each application to gain
authorisation from local authority or other regulatory body is a mandatory requirement.
Other information provided includes details of the planning framework, potential impact
to environment, technology and computer generated photo images, location data sheet
including emission calculations of nearby locations of sensitive use, drawings, antenna
patterns etc. In some cases, information is also provided to interest groups opposed to
the antenna siting. The information flow is facilitated through consultation processes,
information sessions and road shows and is provided in general for a new deployment or
when requested by the public. Operators also upload operational parameters onto the
regulator’s database and provide a bi-monthly discrepancy report between operational
and permitted data. One operator monitors the information exchange process, although
the process is not audited. The feedback from the regulator is positive, whereas public
reaction varies between different communities.
Rec. #2 Operators in Switzerland share sites in various ways like using other operator facilities,
tower and roof-mounted sites, other telecommunication masts and radio installations,
utility’s facilities. One operator reports 60% site sharing in total, 30% sharing with other
operators’ sites (this applies to all operators) and 95% sharing between 3G/2G sites.
Site sharing outside the planning areas of communities is mandatory. The main non-
mandatory reason for sharing is cost saving. A formal administration process for site
sharing is in place. One operator reports that site sharing will remain at about the same
level over the next five years.
Rec. #3 Respondent(s) report use of alternative designs e.g. advertising signs are used for
micro cells and chimneys for roof-top sites when appropriate or required by landlords.
The need of monument protection (city of Berne) requires that antennas are completely
integrated in rooftops, church-towers, etc. No specific guidelines are in place to reduce
.
91
visual impact of sites.

description of services, benefits, possible impact, infrastructure requirements and
timescales of development. Education sessions are held with local authorities before
submission of the building permit application for a new project. The Trade Association
(Forum Mobil) also conducts education sessions annually. It is reported that most of the
time, local authorities are unaware of study results and are not knowledgeable on
technical details. Forum Mobil provides them with information (slideshow) and access to
measurements of EMF fields. Sessions are in generally well received. One operator is
considering deployment of 3G at lower frequencies (resulting in fewer sites). (Note: the
regulator announced that the GSM900 licenses shall be renewed next year technology
neutral. All operators are considering this option in their plans. This will depend on
regulatory approval.
Rec. #5 Operators report base station compliance with national exposure guidelines.
Rec. #6 One operator reports that all sites are certified and that policies for its own employees
when accessing areas close to antennas have been established, together with guidelines
for third parties e.g. painters or construction workers working in or around antennas
(e.g. minimum distance for work on sites which are transmitting of 1.5m otherwise the
site will be switched off). For commissioning a new site one operator performs pre-
installation calculations and measurements and post-installation measurements. Daily
compliancy checks of operational parameters with permitted values are performed.
Measuring the RF exposure in public areas from sites when first commissioned and at
regular intervals subsequently is an integral part of the build permit application and if
80% of the precautionary limit (4 V/m for GSM 900 or 6 V/m for GSM 1800 and UMTS
2100) is reached an on-site measurement is required by law.
Rec. #7 Processes are in place to address issues raised to the company at the national level, or
via Forum Mobil and also to handle individual complaints. The process is facilitated by
specialist staff, being responsible for managing issues with local residents. There are
named contact personnel for liaison with local authorities, telephone hotlines and web-
sites that receive enquiries and dispatch information and Forum Mobil providing
coordination of information exchange.
Rec. #8 The main Swiss operators are founding members of the research foundation for mobile
communications that performs independent research. One operator reports participation
in corporate (group-wide) and national research programmes. Results are published via
media releases and fact-sheets for local authorities and in Forum Mobil’s web site.

Level of It is reported that the level of concern has remained the same over the last 18-24
concern months. GSME Recommendations have not necessarily led to reduction in complaints/
enquiries. Health and environmental concerns are at a high level. Aesthetic and
technology concerns are at a medium level. Other concerns include the impact on the
value of real estate.
Codes of An audit process was performed by the Trade Association. Further information can be
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practice & found at Forum Mobil’s web site. 79

Audit
process
Voluntary It is reported that in most of the cases, local authorities are unaware of study results
actions from and are not knowledgeable on technical details. Operators provide them with
MNOs information on a slideshow and with references with EMF measurements.
Government It is reported that the government takes precautionary actions beyond setting limit
/Other guidelines and provides precautionary advice for the use of mobile phones.
actions
Exposure National (ICNIRP guidelines), Legal requirement from 01/02/2000 – Ref: Ordinance
guidelines concerning protection from non-ionising radiation (NISV) (23/12/1999). At sensitive
locations the emission allowed is 1% of ICNIRP limits.
I.28 United Kingdom

Rec.#1 & 9 All operators have national policies for good practice for network rollout together with a
process to communicate and provide information to the local authority/ the public on
current and future network deployment plans. Operators provide detailed technical and
supporting deployment justifications with each application to gain authorisation from
local authority or other regulatory body, while conduct consultation processes to involve
local communities. The provision of technical operating information on the construction
of each site to the local authority is a mandatory requirement in UK, together with a
monitoring and documentation system for information exchange process. In most cases,
this process is audited and the results are published. Regular surveys are also carried
out by external parties on behalf of the Trade Association (Mobile Operators Association,
MOA) and the operators. Other stakeholders, apart from the regulator, local authorities
and communities are amenity groups and Members of the Parliament. The information is
provided via information sessions/ road shows, seminars, public/ media
announcements, letters to nearby residents, one to one sessions and online consultation
tools. The information provided includes details of the planning framework, potential
impact to the environment and the community, technology and health information. Site
drawings and photo montages are available. Operators may also provide alternative/
discounted sites and ICNIRP Certificate/ letter. In the majority of the cases, the
information is provided in a company’s standard format, in an annual or quarterly report
or when there is a new deployment.
Rec. #2 Operators in UK share sites in various ways: tower site sharing, roof-mounted site
sharing, transmission equipment shelters, antennas, other telecommunication masts
and radio installations, utility’s facilities, lampposts and electricity pylons. Increasing
site sharing over the next five years will be driven mainly by cost saving benefits,
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requirements from licence conditions and the regulator together with environmental and
landscape preservation concerns. Site sharing is administered by formal policies.
Rec. #3 UK operators make use of alternative designs to minimise visual impact, following
specific guidelines in the majority of the cases. There is also planning legislation
requiring sites to be designed to least environmental impact.
Rec. #4 Operators in UK provide information on existing and new services/technologies:

description of services, benefits, possible infrastructure requirements, timescales of
deployment and public consultation information. All operators conduct educational
sessions to explain to the local authority how the technology works or why the sites
have to be deployed in specified locations. The response from the public has been
positive. UK operators are also considering deployment of 3G networks in lower
frequencies, which would reduce future network requirements due to improved
propagation at lower frequencies.
Rec. #5 Operators report base station compliance with European exposure guidelines. UK
exposure guidelines are advised by the Health Protection Agency (formerly National
Radiological Protection Board). These are identical to the EU Council Recommendation
for public exposure and also ICNIRP guidelines for both public and occupational
exposure.
Rec. #6 All sites from reported operators are 100% certified. Radio base stations comply with
the exposure limits in the EU Recommendation and the Physical Agents Directive, risk
assessments and processes are in place to protect employees and third party workers
who need to access areas around antennas (e.g. RF hazard signs are placed at each
site, switch off procedures exist if areas where the occupational limits may be exceeded
need to be accessed by workers, personal EMF exposure monitors provided). RF
exposure site measurements are performed in response to public or others concerns. It
is reported that other requirements in the Directive, e.g. office based staff, health
surveillance are planned to be implemented by December 2007.
Rec. #7 All operators report having processes in place to handle EMF complaints/ inquiries at a
national level, through MOA or individual cases (e.g. consumer or site-specific). These
processes are managed by specialist staff in communication with local residents; there
are named contact personnel for liaison with local authorities; telephone hotlines and
web-sites that receive enquiries and dispatch information; MOA representing network
operators providing coordination of information exchange. The response times of these
processes are monitored.
Rec. #8 UK operators support government research and together with GSMA further
programmes and initiatives. The research programme results are often used to inform
an operator's policy on EMF and health. Research results or the top level/summary
results are also made available to the public/other stakeholders in annual Corporate
Responsibility reports. MOA directs public to research outcomes. Operators also choose
to reference the WHO and other international expert reviews of the global body of
science to which the research programmes contribute. In some cases operator uses a
variety of alerts for all public facing staff involved in deployment, allowing staff to be
better prepared for any questions they may face as part of consultation.
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Level of In UK, the level of concern regarding network rollout has remained stable over the last
concern 18-24 months, with health issues at a high level. Environmental and aesthetic concerns
are at a medium level.
Other concerns include the impact on house prices. It is reported that health and safety
concerns are the main issues, but these often disguise fears of lower house prices
because of the siting and appearance of the installation. The public is also concerned
over siting close to schools, nurseries, playgrounds etc. Operators also report that it is
more difficult to locate suitable search areas for new sites.
Codes of In 2001, MOA published its “Ten commitments to best siting practice” (“Ten
practice & Commitments”) with the object of improving transparency in the process of building
Audit mobile phone networks, providing more information to the public and the 434 local
process authorities across the UK, and increasing the role of the public in the siting of radio base
stations. All elements of GSME Recommendations are captured in the document.
Voluntary One of the Ten Commitments was “to establish professional development workshops on
actions from technological developments within telecommunications for local authority officers and
MNOs elected members”. Since the Ten Commitments were published, MOA has conducted
over 160 such workshops across the UK, and the programme is ongoing. The need to
install more network antennas is communicated to the public. In some cases operators
provide information packs specifically to landlords.
Government Government provide precautionary advice for the use of mobile phones (e.g. reducing
/Other call time, advice for mobile usage by children). UK Government publishes the “Code of
actions Best Practice” on Mobile Phone Network development. There is a continuous review
process of the “Code of Practice” involving national and local government, industry and
pressure groups.
The MOA has an ongoing engagement programme with UK Members of Parliament

(MPs), Members of the Scottish Parliament (MSPs), and Members of the Welsh National
Assembly (AMs) to address any concerns they may raise on behalf of their constituents
relating to mobile phone network development. The MOA also meets with officials and
ministers in the UK Government, particularly with the Department for Communities and
Local Government, the Department of Trade and Industry and the Department of
Health. This engagement programme is replicated with the Scottish Executive and
Welsh Assembly Government. In July 2006, the MOA arranged the first in a series of
joint meetings with three UK Government ministers and Government officials with
responsibility for public health, town planning and telecommunications issues. In 2006,
the MOA published a newsletter for the first time. This newsletter is aimed at MPs, MSPs
and AMs and provides up to date information on network development, town planning
and RF health and safety issues. The newsletter is published twice yearly and future
issues will also be sent to all local authority councillors in the UK.
Exposure EU Recommendation (no legislation) - Ref: “Advice on Limiting Exposure to

guidelines Electromagnetic Fields (0 - 300 GHz)”; Documents of the Health Protection Agency
(formerly NRBP) vol.15 No.2 2004. Adopted “in the terms of the EU Recommendation”
by letter from Government to Health Protection Agency (22/07/2004).
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Annex II – Base Station Planning

Permission in Europe
II.1 Cross-country analysis: Timescales
Requirements and conditions that operators face in order to be granted a permit for base station
deployment vary largely from one European country to the other. Procedures can be defined at
different government levels, even though generally the local authority (municipality) is the main
point of referral for the process. In addition, general requirements related to regional or national
levels legislation usually have to be met.
The figure in the next page summarizes timescales information contained in the countries tables
presented in the remaining part of this Annex.
As a general observation, delays are more likely to occur in cases in which a direct authorizing
intervention of the central government or of a number of bodies other than the local planning
authority is required. This, according to the survey, is true for Belgium, Greece, Spain and
Switzerland. Sweden is an exception, where heavy requirements are counterbalanced by the
efficiency of public offices. Cyprus’ case is characterized by a lack of consistent rules defining the
process more than by heavy bureaucracy per se.
On the other hand, countries such as Italy and Portugal have implemented tacit approval
mechanisms to avoid delays related to bureaucratic inefficiencies. In other countries with
relatively short timescales for granting of permission operators may benefit from effective
systems of exemptions for smaller sites and site upgrades (the Netherlands and the UK are two
examples).
When comparing this data with the 2004 report commissioned by GSM Europe on the same
topic 80 we notice that timescales for permission granting have not changed dramatically. The
most relevant difference is represented by Czech Republic, in which the new Building Code
recently issued has implemented a leaner and more effective procedure.
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df
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Figure II.1 Comparison between legal commitment and typically achieved timescales for
granting planning permission on a per country basis
24
18
12
Lithuania
Finland
Ireland
Bulgaria
Republic
Netherlands
Belgium
Switzlerland
Austria
Slovenia
Denmark
Hungary
Italy
Spain
Poland
Portugal
Slovakia
Latvia
Malta
Romania
France
Germany
Cyprus
Kingdom
Greece
Sweden
United
Czech
The
legal commitment typical achieved
II.2 Country data
II.2.1 Austria
Planning Authority Municipality
Requirements for Vary according to location. Every province has its building and
planning landscape protection laws. In addition, permissions relative to
permission federal laws have to be obtained if relevant (ex. Protection of the
woods).
Timescales for From 6 months to up to 2 years. Typically 1 year.

Permission
Appeals process Process goes through instances by different administrative

authorities – generally 3 until the Supreme Court.
Public Consultation Not mandatory. Operators can set pre-planning meetings with
local authorities and information sessions with local communities
prior to site erection.
Exemptions & Exemptions depend on provinces regulations. Upgrades need to

Existing site follow the same procedure as new sites unless the original
upgrade permission was taking them into account.
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II.2.2 Belgium
Planning Authority Regional administrations
Requirements for Planning has to comply with regulations at all levels of

planning governments (local, regional, federal). Permissions are required
permission for telecom towers and street lampposts. A new ‘radiation
certificate’ is also needed for all sites. It is issued from the
Federal regulator and for the south of the country via the Issep.
Timescales for The average is 18 months. Individual actions can make the
Permission process last for 3 years.
Appeals process Appeals go directly to the relevant Ministry or Council of State.

The appeal process takes from 6 to 18 months.
Public Consultation Local authorities publish notices on sites and make information
available in the Town Council offices.
Exemptions & Upgrades do not need new permits, extensions do. However,
Existing site structures less than 4m higher than the highest point of the
upgrade building are exempted.
II.2.3 Cyprus
Planning Authority Municipality and Ministry of Interior’s Planning and Housing
Department
Requirements for Even though the Government in 2005 has laid out new legislation
planning to unify permissions procedures, its implementation is still
permission pending. Requirements may vary on a case-by case basis and
operators lament lack of coherency and clarity.
Timescales for The original provision of 6 weeks contained in the new legislation
Permission has remained unapplied. Typical timescales go up to 2 years.
Appeals process Appeals go through administrative courts.
Public Consultation Not mandatory, but requirements may vary.
Exemptions & Upgrade applications are evaluated by the Municipality only and
Existing site do not require approval from the Ministry.
upgrade
II.2.4 Czech Republic

Planning Authority Municipality’s building department
Requirements for Generally, a planning permission is required for new BTS. For
planning rooftop structures a planning permission has to be granted, while
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98
permission for open landscape structures reporting activity to the building

department is needed in addition to this planning permission.
Timescales for 1 to 8 months. The legal commitment of granting permission in 2

Permission months is respected in the majority of cases.
Appeals process If the permission is not granted and appeal can made within 15
days to the local administration or within 60 days to the
administrative court.
Public Consultation Citizens may submit comments only in cases when permission is
needed.
Exemptions & Upgrade is allowed without further permission if it does not

Existing site involve any change in terms of construction work.
upgrade
II.2.5 Denmark
Requirements for Building permits. The applicant has to inform the National
planning Telecom Agency about the application process.
permission
Timescales for Generally 3 to 6 months. Worst cases up to 2 years.

Permission
Appeals process Appeals can be made to the Ministry of Internal Affairs.
Public Consultation The municipality has to inform the citizens impacted.
Exemptions & Simple upgrades or sharing of sites do not require further

Existing site permissions.
upgrade
II.2.6 Finland
Planning Authority Municipality. Procedure defined by the regulator (FICORA)
Requirements for A building permit is required. An impact analysis has to be

planning attached to the application together with an evaluation of options
permission such as usage of existing sites. For base stations higher than 15
meters permission from the civil aviation authority is needed.
Additionally, special permissions have to be granted before
building permits if a town plan is not in place.
Timescales for 1 to 24 months, average 6.

Permission
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Appeals process Appeals can be made within 15 days to the local administration of
within 30 days to the Provincial Administrative Court. This can
lead to delays of up-to 2 years.
Public Consultation The operator has to inform the community and make information
available at the local municipality offices.
Exemptions & None

Existing site
upgrade
II.2.7 France
Planning Authority Mayor
Requirements for A building permit is needed for equipment higher than 4m and/or
planning with a footprint greater than 1.5 x 2m. In addition, the urban
permission planning code must be complied.
Timescales for Permissions must be granted within 2 months.

Permission
Appeals process Appeal procedures are handled by administrative courts.
Public Consultation A consultative process is handled by the regulator in response to

complaints.
Exemptions & None

Existing site
upgrade
II.2.8 Germany
Planning Authority Local planning authorities and BnetzA
Requirements for A site certificate from BnetzA is mandatory for all sites. This
planning ensures compliance with exposure guidelines and other technical
permission requirements. Permission from local planning authorities is
mandatory for all installations higher than 10m. Once the site has
been constructed and before it is activated emissions authorities
have to be notified.
Timescales for Typically less than 6 weeks. More than one year in worst cases.
Permission
Appeals process Legal proceedings against the local authority can take up to 3
years, but these occur in rare cases if the operator fulfils all the
requirements for the process of site acquisition.
Public Consultation A public consultation process with local communities is mandatory
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100
for all operators and has to start before the application for a site
certificate.
Exemptions & In several states (but not all) there are exemptions for installation
Existing site with poles/masts below 10m and shelters of less than 10m3.
upgrade Upgrades of existing sites have to follow the same process as new
sites unless the compliance area of the planned installation lies
completely within the compliance area of the existing installation.
II.2.9 Greece
Planning Authority Building authorities and others setting regulations for related
issues. These include: HCAA (Hellenic Civil Aviation Authority),
GAEC (Greek Atomic Energy Committee), NTPC (National
Telecommunications and Post Committee - Greek Regulator),
Prefecture/Region (for Environmental Impact Studies - EIS),
Archaeology (3 separate authorities), Forestry/Prefecture.
Requirements for There are many steps that should be followed in order to have
planning planning permission. These steps include addressing, among
permission others, EMF, telecommunication, constructional and
environmental issues.
Timescales for Typically between 2 and 3 years.

Permission
Appeals process A petition for annulment may be brought against the decision of
the General Secretary of the Region. The hearing of said petition
takes place within one month as of its filing and the Court issues
the respective decision two months thereafter. An appeal before
the Supreme Administrative Court of Athens may be filed against
the decisions of the aforementioned Administrative Court of
Appeal and the respective hearing takes place within three
months as of the filing of said appeal.
Public Consultation No public consultation process takes place except in the context
of Environment Impact Study approval.
Exemptions & For base stations with transmission power EIRP<164 Watts the
Existing site GAEC approval is not necessary. In the most micro-sites cases
upgrade (EIRP<16.Watts) the licensing requirement is only a declaration
of site installation specifications to NTPC. For upgrades: in case
of no structural alterations only a revision of GAEC and EIS
(Region) and declaration of upgrade specifications to NTPC are
needed. If the upgrade involves structural alterations of site there
must be a complete revision of all licenses.
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II.2.10 Hungary
Planning Authority Local civil authorities as part of the local municipalities
Requirements for Construction permission is required for all new sites. General
planning technical requirements are set by the National Construction
permission Constitution.
Timescales for The authority should respond within 60 days but typically it takes
Permission 6 months to get a permit. Worst cases 2 years.
Appeals process If the local municipality does not give permission the operators
can put a request to the regional authority. At the third stage the
administrative court intervenes. This may lead to a one year
delay.
Public Consultation Public consultation with local communities is not mandatory.
Exemptions & Site upgrades must follow the same process as new sites – no
Existing site exceptions.
upgrade
II.2.11 Ireland
Planning Authority Local Authorities
Requirements for All deployment is governed under the National Planning Act.
planning Support structures need planning permissions.
permission
Timescales for 2-3 months typically.

Permission
Appeals process If refused by Local Authority, request can be sent to a Planning

appeals board for consideration. This leads to up to 6 months of
delay.
Public Consultation Planning application must be posted on site, notice in newspapers

and plans available for inspection at Local Authority Offices.
Voluntary meetings with local communities may take place.
Exemptions & Exemptions apply to upgrades involving antennas of less than

Existing site 12m on existing masts and to commercial buildings where the
upgrade antennas don't rise 2m above the roof.
II.2.12 Italy
Planning Authority Municipalities (planning issues and overall responsibility for the
authorization process) and Regional Environmental Authority
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102
(providing advice to Municipality on the EMF impact of each Radio

base Station).
Requirements for Planning permission is required in order to construct a new site in

planning Italy. Compliance with the national electromagnetic field exposure
permission limits, specific urban planning and building rules are required. In
addition, town planning regulations must be met if in place.
Timescales for Decree no. 259/2003 has established that if local authorities do
Permission not oppose an authorization request within 90 days, the
authorization is considered to be effective.
Appeals process Appeals decisions are assigned to regional administrative courts.

In second instance the administrative court of the Lazio region
intervenes. The process can be delayed of up to 3 years as a
consequence.
Public Consultation The regional environmental agency has to be consulted as part of

the permission procedure.
Exemptions & Decree n. 259/2003 has established a process for site upgrades
Existing site which is very similar to the process for a new site installation. A
upgrade new EMF advice has to be issued by the Regional Environmental
Authority, even for changes of radio parameters only (e.g. tilt
modifications, new transmitters leading to power output increase,
etc.). However, sites with power below a set threshold are
excluded.
II.2.13 Lithuania
Planning Authority Local councils and NRA
Requirements for General requirements for planning permissions include EMF pre-
planning calculation.
permission
Timescales for 1 to 24 months. Typically 6.

Permission
Appeals process If permission is not granted reiteration is allowed.
Public Consultation Not mandatory.
Exemptions & Procedure for upgrades is much leaner.

Existing site
upgrade
II.2.14 Malta
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103
Planning Authority Malta Environment and Planning Authority (MEPA)
Requirements for Planning permission required only when proposed base station is
planning on sensitive building or area.
permission

Permission
Appeals process Submission to MEPA appeals board.
Public Consultation In cases where a planning permission is required the application

will also be made public for informative purposes.
Exemptions & No permits required for normal installations in non-sensitive sites

Existing site or buildings.
upgrade
II.2.15 The Netherlands

Requirements for The National Antenna Policy sets tiers of requirements according
planning to size of masts: full (more than 40m), light (5 to 40m).
permission Installations shorter than 5m do not need a permit but
requirements are adjusted with the involved landlords.
Timescales for Permissions with light requirements normally take 3-5 months.
Permission Full requirements permissions take 9 months to be granted.
Appeals process Appeal processes go through civil courts and this can take up to 5
months of delay.
Public Consultation The self-regulatory agreement of the industry with the

government foresees a mandatory consultation with municipalities
(at least once a year) and with tenants of residential buildings.
Exemptions & Most upgrades are permit-free – depends on construction and

Existing site environmental impact.
upgrade
II.2.16 Poland
Planning Authority Municipality or local government
Requirements for Requirements are defined at the national level through five acts:
planning Spatial Development Rules, Building Permission, Environmental
permission Law, Permission for EMF emission and Permission for operation.
Timescales for Between 6 months and 3 years. Normally 1 year.
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104
Permission
Appeals process Appeals can go through 3 instances to Local, Provincial and High
Courts. This leads to up to 3 years delay.
Public Consultation The local authority has to provide information to the public. Public
consultations take place as meetings but are not mandatory in
most cases.
Exemptions & Upgrades go through the same process as new sites.

Existing site
upgrade
II.2.17 Portugal
Requirements for A building permission is needed for all new sites. Decree-Law
planning 11/2003 regulates it. In all cases compliance with radiofrequency
permission exposure limits and specific urban planning and building rules
must be met. Rooftop installations on residential buildings require
an authorization from owners.
Timescales for The local municipality has to clear a request in 30 days.

Permission Otherwise, tacit approval.
Appeals process Through administrative courts. Delay up to 2 years.
Exemptions & Temporary base stations and site upgrades do not need planning
Existing site permissions.
upgrade
II.2.18 Romania
Requirements for Building permit (requires lease contract and construction project),
planning Radio Emitter Permit from National regulator and Public Health
permission Office impact study.

Permission
Appeals process Negotiation processes or finding new sites are generally preferred
to formal appeal.
Exemptions & Upgrades go through the same process as new sites.
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105
Existing site
upgrade
II.2.19 Slovakia
Planning Authority Local authorities, Telecom Office, Ministry of Health,
Environmental Offices
Requirements for Requirements at the national level are defined by the

planning Construction Act, Electronic Communication Act, Public and
permission Occupational Health Protection Act, Law on Nature Protection Act.
Timescales for 3 to 12 months.

Permission
Appeals process Appeals can be made to higher-level government authority.
Exemptions & If a site upgrade qualifies for a "minor construction", the process
Existing site for obtaining building permit is shortened. Otherwise, there is no
upgrade exemption for upgrade, and the regular construction permit
process applies. In case of antenna upgrade, new power output
measurement is necessary.
II.2.20 Slovenia
Planning Authority Municipality and Ministry of Interiors
Requirements for Base stations shall be designed fulfilling requirements contained

planning in the National Building Code. The relevant authority to evaluate
permission the request is the local municipality in cases for simple object
such as rooftops up to 10m. The Ministry instead has to evaluate
requests related to complex objects, such as new towers.
Timescales for Typically 6 months.

Permission
Appeals process Appeals go through a standard administrative suit procedure.
Public Consultation Local authorities evaluate on a case-by-case basis whether a

public hearing with affected neighbours is mandatory.
Exemptions & No exemptions. Existing site upgrades considered as investment

Existing site maintenance. All upgrades shall comply with EMR limits.
upgrade
II.2.21 Spain
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106
Planning Authority Municipality and Ministry of Industry
Requirements for The agreed standard procedure requires a building permit from
planning the local municipality and a ministerial emissions authorisation,
permission for which a pre-construction technical report including an
environmental impact assessment has to be produced.
Timescales for Administrative proceedings should be closed within 6 months

Permission according to Spanish law. However, procedures for base station
planning take on average 18 months, with peaks of 3 years.
Appeals process A first appeal can be made to the local administrative authority.
In second instance the standard judicial proceeding has to be
followed.
Public Consultation A public consultation on environmental impact is required in most

Autonomous Communities.
Exemptions & No specific exemptions. For upgrades a further application has to

Existing site be submitted to the Municipality and the Ministry. It is their
upgrade discretion to regard is as an adaptation or a new permission
request.
II.2.22 Sweden
Requirements for Each green field base station requires a full planning permission.
planning Compliance with regulations from the Swedish Airport Navigation
permission Service and the Swedish Armed Forces must be met.
Timescales for Typically 2 months. Worst cases are delayed up to 2 years.

Permission
Appeals process Different stakeholders can appeal to the next-level court

(sequence: local government, county administration,
Administrative Court, Administrative Court of Appeal and
Supreme Administrative Court).
Public Consultation Each municipality can decide whether to impose a consultation in

whichever extent and manner.
Exemptions & No exemptions. Upgrades do not need to comply with additional

Existing site requirements.
upgrade
II.2.23 Switzerland
Planning Authority Local and/or State authority (see below)
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107
Requirements for The local authority issues the build permit for base stations within
planning the construction zone: this requires compliance with canton and
permission federal law (construction law, environmental law, EMF regulation,
nature- and country protection law). For base stations outside the
construction zone an additional permit from the canton (state) is
necessary. Additional permissions are necessary in sensitive
zones (landscape protection zones). Further special regulations
and processes are applied for base stations on power pylons, on
train properties or on highways. For all build permit applications a
positive statement of the environmental authority concerning
compliance with the environmental law is mandatory.
Timescales for 3 months to 3 years. Typically one year.

Permission
Appeals process Each stakeholder can appeal through 4 instances (typical

sequence: communal authority, canton government, canton
administrative court, Swiss Federal Court).
Public Consultation Public consultation is mandatory and information on every plan

has to be provided. Each neighbour living in a distance of 300-
750m (depending on power) is considered as stakeholder.
Exemptions & Micro-cells with a total power below 6W are exempted. Upgrades
Existing site need a full permitting process is direction is changed or
upgrade transmission power increased.
II.2.24 United Kingdom

Planning Authority Municipalities in England, Scotland and Wales. In Northern Ireland
Central Planning Service
Requirements for Standardised planning procedures for masts below 15m and
planning enclosed within defined cubic limits (prior approval or permitted
permission development). These are defined by a specific Mobile Operators
Association Code of Best Practice. Full procedures are required for
bigger masts or for all base stations in Northern Ireland.
Timescales for 8 weeks if no opposition. 18 months in worst cases.

Permission
Appeals process A first appeal can be presented to the same authority as original
application. If refused operators can refer to the Planning
Inspectorate (governmental agency). There is no third party right
of appeal.
Public Consultation Pre-consultations are carried out by operators following the Code
of Best Practice. A Public consultation is mandatory only for sites
requiring full procedures.
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Exemptions & Masts below 15m can go through a simplified procedure (see
Existing site above). Minor upgrades are permitted for non-sensitive areas.
upgrade
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109
Annex III – GSM Europe Health &

Environment: Recommendation on Network
Rollout Good Practice
GSM Europe and the mobile telecommunications industry in Europe recommends good practice
in the deployment of mobile telecommunications networks and encourages dialogue and
consultation with key stakeholders.
Key elements of the mobile telecommunications industry recommended good practice include:
Rec. #1 Improving the dialogue with local authorities and other key stakeholders in order
to increase understanding of network infrastructure requirements and local
planning frameworks. The consultation process will take into account planning,
environmental and community issues.
Rec. #2 Considering site sharing with other radio installations or existing structures, where
technically feasible and in line with competition law and licensing conditions, when
decisions are being made on the most environmentally appropriate radio base
station solution.
Rec. #3 Sensitive siting and design, which reduces visual intrusion and can help allay
public concerns. The industry recognises that the environmental impact of radio
base station developments should be kept to a minimum.
Rec. #4 Providing information to regulatory and planning authorities on mobile

telecommunications technological developments. The industry believes that the
provision of technological information is an effective means of raising awareness
and understanding of the issues confronting the industry.
Rec. #5 Ensuring all existing and new radio base stations comply with national exposure
guidelines based on the public exposure guidelines of the International
Commission on Non-Ionizing Radiation Protection (ICNIRP), as expressed in EU
Council recommendation of 12 July 1999 (Reference 1999/519/EC) on the
limitation of exposure of the general public to electromagnetic fields (0 Hz to 300
GHz). The industry supports exposure guidelines, such as ICNIRP, which are based
on sound scientific evidence and are subject to on-going expert review.
Rec. #6 Providing a written declaration that radio base stations are designed to comply
with national or European exposure guidelines. A signed declaration of compliance
with the relevant guidelines supports openness and provides confidence to local
communities that radio base stations are being operated safely.
Rec. #7 Implementing a clear process to respond to complaints and enquiries about radio
base stations. The industry recognises that there has often been some frustration
regarding the information provided when enquiries are received on radio base
station sites and that the quality of the information provided to the public needs to
.
110
be of a high standard.
Rec. #8 Supporting quality research programmes at the EU and Member State level based
on the WHO research agenda that will provide the basis for on-going review of
established guidelines. Expert reviews in a number of EU states have concluded
that there is no convincing independent scientific research of a link between public
exposure to the low level radio signals used by mobile telecommunications
systems and adverse human health effects. However, the industry welcomes on-
going, independent, quality research programmes in order that policy can be
based on substantiated scientific evidence and criteria.
Rec. #9 Using clear and consistent supporting documentation when exchanging

information with regulatory and planning authorities. The industry recognises that
it is often confusing when presented with similar information in varying formats
and therefore documentation will aim to follow defined formats.
.
GSM Association
(London offices)
1st floor Mid City Place
71 High Holborn
London
WC1V 6EA
Tel: +44 (0)20 7759 2300
Fax: +44 (0)20 7759 2301
info@gsmworld.com
www.gsmworld.com
GSM Europe
Diamant Building
80 Bd. A. Reyerslaan
1030 Brussels
Belgium
Tel: +32 2 706 8105
Fax: +32 2 706 8108
gsme@gsm.org
www.gsmeurope.org

Health and Environment Building Mobile Networks 2007 - English

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Health and Environment Building Mobile Networks 2007 - English

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GSM Europe Health &

Ovum Consulting, Cardinal Tower, 12 Farringdon Road, London EC1M 3HS

2.1 Study and scope of work ..........................................................................................12

2.2 Report structure ......................................................................................................12

2.3 Social and economic contribution of mobile communication............................................13

2.4 Mobile technology and network infrastructure ..............................................................13

2.4.1 How mobile networks work.....................................................................................13

2.4.2 New technologies and service evolution....................................................................14

2.5 The need for continuous base stations deployment .......................................................15

2.6 GSM Europe’s activities ............................................................................................16

3. Implementation review of GSM Europe Recommendations ..................................... 20

3.1 Background ............................................................................................................20

3.2 Survey participants ..................................................................................................20

3.3 General conclusions across the EU .............................................................................21

3.4 The impact of GSM Europe Recommendations..............................................................25

3.5 General conclusions .................................................................................................36

4. Research support .................................................................................................... 38

4.1 Background ............................................................................................................38

4.2 Current status: European Commission - EU .................................................................38

4.3 The involvement of GSM Europe and GSMA .................................................................40

4.4 International Research .............................................................................................41

4.4.1 World Health Organization......................................................................................41

4.4.2 Precautionary policies ............................................................................................42

4.4.3 Other reports .......................................................................................................43

Annex I - Country profiles ........................................................................................... 45

I.1 Austria ...................................................................................................................46

I.2 Belgium ..................................................................................................................48

I.3 Bulgaria ..................................................................................................................49

I.5 Czech Republic ........................................................................................................53

I.7 Estonia ...................................................................................................................55

I.8 Finland ...................................................................................................................55

I.9 France ....................................................................................................................57

I.14 Italy .....................................................................................................................68

I.15 Latvia ...................................................................................................................70

I.17 Luxembourg ..........................................................................................................73

I.18 Malta ....................................................................................................................74

I.19 The Netherlands .....................................................................................................75

I.20 Poland ..................................................................................................................77

I.21 Portugal ................................................................................................................79

I.22 Romania ...............................................................................................................81

I.27 Switzerland ...........................................................................................................90

I.28 United Kingdom .....................................................................................................92

Annex II – Base Station Planning Permission in Europe ............................................. 95

II.1 Cross-country analysis: Timescales............................................................................95

II.2 Country data ..........................................................................................................96

• Operators use a variety of methods to inform key stakeholders, primarily local

Letters to nearby residents 38%

Public/ media announcement 35%

Source: Ovum for GSME Study

Source: Ovum for GSME Study

Named contact personnel for liaison with local

Employment of specialist staff for

Telephone hotlines and web-sites that receive

Established Trade Association representing

Established processes in the handling of

0% 20% 40% 60% 80% 100%

Source: Ovum for GSME Study

o companies with multi-national operations may have network rollout guidelines

Figure 1.6: Trends in the level of concerns (last 18-24 months)

Increased Decreased No change

Health 39% 8% 53%

Environment 28% 5% 67%

Aesthetic 19% 6% 75%

Technology 3% 14% 83%